As the COVID-19 pandemic has evolved, our dedication to our patients, team, and community has remained steadfast. As an organization, we are committed to doing all we can to protect the health and well-being of our teams and our patients. Since announcing our vaccine requirement in August, a vast majority of our team members have become fully vaccinated. The COVID-19 vaccine still provides the clearest path out of this pandemic, and we are grateful that so many of our colleagues have taken this important step to protect their family, friends, patients, and community.
The Centers for Medicare and Medicaid Services (CMS) recently published an emergency regulation that applies to Medicare and Medicaid-certified providers, like Kettering Health. This regulation requires us to have a policy in place ensuring that staff are vaccinated against COVID-19. The term “staff” is defined to include all current and new employees, students, volunteers, medical providers with medical staff and admitting privileges, and contractors who have contact with staff and patients. After extensively reviewing the regulations, we need to update portions of our vaccine requirement policy to ensure it is in compliance.
Exemptions update
Medical and religious exemptions
The CMS regulation does allow us to accept legally required medical and religious exemptions. Those who have already received a medical or religious exemption do not need to take any further action and will still be considered compliant with our COVID-19 vaccine requirement.
Temporary exemptions
The CMS regulation does not allow us to accept the temporary exemptions we granted to those who attested that they are pregnant, trying to conceive, breastfeeding, or naturally immune from COVID-19 based on a prior COVID-19 infection. These exemptions did not require a licensed practitioner to confirm the recognized clinical contraindications to the COVID-19 vaccines and also state which COVID-19 vaccines are not recommended.
In order to remain compliant with the CMS regulation, we are required to revoke all of these temporary exemptions, effective immediately. Anyone granted a temporary exemption/deferral is now considered non-compliant and is required to become compliant with the CMS regulation by either receiving the COVID-19 vaccination by the deadlines outlined below or by applying for and receiving a legally required medical or religious exemption.
For those individuals who are pregnant, trying to conceive, or breastfeeding and have concerns about the COVID-19 vaccine, there is a forum hosted by women’s health providers where concerns related to these important issues are addressed.
New/extended deadline to submit medical or religious exemptions
Please note that we will be re-opening the window to submit an exemption until 11:59 p.m. on November 24, 2021.
Anyone currently non-compliant with the vaccine requirement is eligible to submit a medical or religious exemption using the updated exemption forms attached to this email. Those exemptions will be reviewed and approved in accordance with Title VII or the ADA. However, if you have submitted an exemption and that exemption has been denied, you may not resubmit the same exemption request unless that exemption was denied as untimely because it was submitted after October 15. Updated medical and religious exemption forms are also available here.
Note: You must be connected to Kettering Health’s network to access these forms. Submissions must be emailed as a PDF to EHPrograms@ketteringhealth.org before 11:59 p.m. on November 24, 2021.
Testing in lieu of vaccination
The CMS regulation does not allow testing in lieu of vaccination.
Compliance timeline
We are adjusting our timeframe to align with the CMS regulation. Employees must receive the first dose of the COVID-19 vaccine (regardless of what vaccine you choose – Pfizer, Moderna, or Johnson & Johnson) by December 5 and the second dose of the COVID-19 vaccine by January 4. Employees who are not in compliance with these deadlines will be issued a final written warning on December 6 and removed from the schedule (per CMS requirements). Employees who are non-compliant as of January 4 will have their employment terminated. Non-employees who fail to meet these deadlines will not be permitted to enter into or do business in our facilities.
Note: Employees already on a final written warning as of December 5 who are non-compliant with the vaccine requirement (i.e. have not received the first dose of the vaccine), will be terminated.
Remote workers
Employees who are fully remote and work 100 miles or more from a Kettering Health facility are exempt from the COVID-19 vaccine requirement. We have taken this position with the understanding that we may need to call team members in (who live within 100 miles of a KH facility) to help out as part of our disaster response plan.
For further details about these updates, please refer to our FAQ document. We are updating that document and it will be available for review by noon on Friday.
Our same commitment and focus to the safety and well-being of our community—including our team members—has been paramount since the onset of the pandemic. This has meant we have needed to also adapt our processes, protocols, and procedures to ensure our response aligns with the latest data, research, and guidance available. The last few years have brought countless challenges and changes—but they have also revealed the strength of our team. As we’ve continued to serve our community and adapt to the ever-changing situation, you have faced each surge and shift with grit, compassion, and grace.
Thank you for your commitment to each other, to our patients, and our community.