Updated December 17, 2020.
As has been widely publicized, at least three coronavirus vaccines have been developed and are ready for distribution. The vaccine manufacturers include pharmaceutical companies Pfizer, Moderna and AstraZenica. Pfizer’s vaccine received emergency use approval by the United States Food and Drug Administration (FDA) on December 11, and distribution began on December 13. Approval of the Moderna and AstraZenica vaccines is also expected in short order.
Pfizer and Moderna report a 95% effective rate in early clinical trials. AstraZenica’s numbers are a bit lower – between 70% and 90% depending on dosage. However, the AstraZenica vaccine has an advantage over the Pfizer and Moderna versions, as it can be stored, transported and handled in standard refrigerated conditions. The Pfizer and Moderna vaccines require super cold (-70 degrees) storage, so they’ll be more difficult to broadly distribute where refrigeration equipment may be lacking.
With emergency use approval granted or in the works, the Centers for Disease Control (CDC) has continued working closely with state public health departments, healthcare associations and pharmaceutical companies on flexible COVID-19 vaccination programs that can accommodate various different vaccines. One key priority is to ensure that vaccines are available to all communities, and that they can be administered in various settings such as doctor’s offices, retail pharmacies, hospitals and federally-qualified health centers. Initial distribution of the Pfizer vaccine has been to hospitals to begin vaccinating healthcare workers.
Given that supply will be limited at first, the CDC will look to the Advisory Committee on Immunization Practices (AICP) for recommendations on which groups will be initially eligible for a vaccine. ACIP’s recommendations will likely include healthcare workers, workers in essential and critical industries, people 65 years and older, and people at high risk due to existing health conditions. The Indiana State Department of Health (ISDH) indicates that long-term care center staff and healthcare personnel who are at heightened risk of exposure will receive the first round of vaccinations when they arrive. To get an idea of your place in line, check out this vaccine tool.
My colleague Ryan Bojrab, Senior Director of Health Strategy, talked with Scott Jones of FOX59 News about whether employers can require vaccinations and how people leaders like you can approach the next few months.
Health Plan Coverage and Costs
The CARES (Coronavirus Aid, Relief, and Economic Security) Act requires employer-sponsored health plans to cover a COVID-19 vaccine at no cost to plan participants for the duration of the public health emergency. On October 28, the Departments of Health and Human Services, Labor, and Treasury jointly issued an interim final rule implementing this requirement. Under this rule, group health plans and health insurers must cover COVID-19 vaccines within 15 business days of approval by the CDC. Coverage must be provided with no cost sharing regardless of whether the vaccine was administered by an in-network or out-of-network provider. This rule also holds true for individual policies, Medicare and Medicaid. As a practical matter, this coverage will likely be added immediately upon a vaccine’s approval.
While the CARES Act coverage mandate does shift additional costs to employers, these costs aren’t anticipated to be significant. The recently released Medicare payment rate for a two-dose COVID-19 vaccine is $45.33. Although providers often charge employer health plans a rate higher than Medicare, it’s not likely that the price of the vaccine will increase substantially over the Medicare rate, as the majority of development costs have been funded through government grants. According to a recent article in Forbes, Pfizer set initial pricing at $19.50 per dose. Other developers are expected to publish similar pricing.
And, although health plans will bear the cost of these vaccines, it’s likely to be a financial win due to the avoidance of the COVID-19 infection. The cost of contracting the virus could be significantly higher depending on the severity of the case.
Should You Require Employees to Be Vaccinated?
Once vaccines are readily available, you may wonder if you should require employees to get one. The EEOC issued guidance on December 16, 2020 specifically addressing workplace issues and the COVID-19 vaccine.
The new EEOC guidance is consistent with guidance in past pandemics (such as H1N1 in 2009) and permits employers to enforce a vaccination requirement, as long as accommodations under Title VII and the Americans with Disabilities Act are made. This means that employees who have a qualified disability under ADA that prevents them from getting a vaccine must be exempt. Employees with sincerely held religious beliefs against vaccinations must also be exempt from the requirement.
Finally, state laws can come into play as well. Although several states currently require influenza vaccines for healthcare workers, other states – including Indiana – encourage vaccinations but do not require it.
What is clear from this guidance is that you will want to carefully consider whether to require your employees to get the vaccine. While it may be legal to do so, the question of whether it’s advisable is an important one to ask. This is an area where individually-held beliefs are often strong one way or the other. There are also individuals who will fear the vaccine, and you should take those fears into account when implementing a vaccine policy.
Adopting a COVID-19 Communication Strategy
Whether your organization does or doesn’t require the vaccine, a clear communication strategy about your policies will be important now and once the vaccinations become available. As the circumstances of 2020 have made clear, this is a time where people feel vulnerable and often isolated. An empathetic communication approach that advises employees of plan coverage provisions, options for where to get the vaccine (once available), and rationale for requiring or recommending the vaccine will be critical. Above all, the message to employees the health and safety of employees and their families is top priority must be loud and clear.
For more internal communications ideas, be sure to check out these other blogs:
- The Key to Understanding Individual Communication Preferences
- Five Reasons Your Open Enrollment Should Go Digital
- Employee Benefits Communication: A Key to Positive Business Outcomes
The First Person team is closely monitoring the status of vaccine approval and related guidance, and will continue to update this article as more information is released.
For a more intimate look at the regulations and strategies you can implement now, join your fellow HR leaders for an on-demand replay of How the 2021 Political Landscape Impacts You.