COVID-19: Vaccination Program Policy comment period extended

On Aug. 30, 2022, the Policy on Vaccination Programs – With Interim Amendments was issued, with an effective date of Sept. 1, 2022. On Sept. 16, 2022, the University of California Office of the President distributed a draft policy for Systemwide Review with a comment deadline of Dec. 15, 2022. Based on feedback received from the Systemwide Review thus far and discussions with leadership, updated interim amendments were made to the policy to include an option for members of the University community to opt out of COVID-19 boosters as well as technical edits. On Dec. 12, 2022, the Policy on Vaccination Programs – With Updated Interim Amendments was issued.

In light of these updated interim amendments, the Office of the President is distributing an updated draft policy and extending the comment deadline for the formal Systemwide Review and consultation process from Dec. 15, 2022, to Jan. 31, 2023, to finalize this Presidential Policy.

Key revisions from the updated interim amendments include the following:

• The Primary Series of the COVID-19 vaccination will remain mandatory for all incoming faculty, staff, students, and trainees who are Covered Individuals subject only to religious, medical, and disability exceptions and temporary deferral due to pregnancy or recent COVID-19 diagnosis or treatment. (Health care workers will continue to be eligible for fewer exceptions due to a California Department of Public Health order.)
• Covered Individuals must be up-to-date with COVID-19 vaccination boosters. However, those who prefer to opt out of COVID-19 boosters will be permitted to do so by signing a declination statement after receiving education and subject to non-pharmaceutical interventions specified by their locations (for example, masking).  Please note that health care workers may not decline their first booster under a California Department of Public Health order unless they are eligible for one of the order's limited exceptions or deferrals.
• If a Covered Individual prefers to defer the COVID-19 bivalent booster for more than 90 days after being diagnosed with or treated for COVID-19, they can do so by declining the booster after receiving education. When they do receive the booster, they will again be considered Up-to-Date.
• Locations will ordinarily set an annual compliance deadline between July and December for existing faculty, staff and students to participate in the COVID-19 vaccine program. This year Locations may set that deadline as late as Feb. 1, 2023.

The version of the policy distributed on Sept. 16, 2022, renamed the policy “Policy on Vaccination Programs” and consolidated the University's existing systemwide vaccination requirements other than the Student Immunization Policy into a single document. Key revisions that were distributed for Systemwide Review at that time include the following:

• The COVID-19 Vaccination Program Attachment incorporates language from the July 15, 2021, SARS-CoV-2 (COVID-19) Vaccination Program policy with a focus on reorganization and simplification of existing policy language. Those updates were not intended to institute substantive changes in policy regarding existing COVID-19 vaccination requirements.
• In alignment with CDC guidance, the deadlines for completion of the primary COVID-19 vaccination series have been extended to allow for a longer interval period between doses.
• Locations are encouraged to evaluate COVID-19 Vaccination Program Participation, but Healthcare Locations are not required to do so.
• The COVID-19 Vaccination Program corrective action/discipline language for policy-covered academic appointees has been clarified.
• The Seasonal Influenza Vaccination Program Attachment incorporates language from the President's past flu vaccine Executive Orders. The Seasonal Influenza Vaccination Program is an Opt-Out program, which means Covered Individuals may decline vaccination after receiving vaccine education. The program has an annual compliance date of no later than Dec. 1. Locations may choose an earlier compliance date. The first compliance date for new employees depends on when their first date of employment is in relation to the flu season. 
• The language has been updated throughout consistent with current public health usage.

The draft policy is posted on UCNet, and can also be accessed at https://ucanr.edu/sites/PCPA/Revisions/. 

If you have any questions or if you wish to comment, please contact Robin Sanchez at rgsanchez@ucanr.edu, no later than Jan. 25, 2023. Please indicate “Vaccination Programs Policy” in the subject line.

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