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July 6, 2022

Note: View details on the steps to submit information to the UNC Health web portal at this link.


Why is UNC Health requesting COVID-19 vaccine information for vendor personnel?
The COVID-19 Vaccination Rule and related guidance established by the Centers for Medicare & Medicaid Services (CMS) requires COVID-19 vaccination for healthcare personnel and requires healthcare facilities to track and document vaccination and exemption status for healthcare personnel, including vendor and contractor personnel (known as “Covered Workers” under our process).

 

Does this requirement apply to all my staff, even those who visit a UNC Health patient care facility for only a short period of time?
The COVID-19 vaccine requirement applies to any of your personnel who visit or work at a UNC Health location or facility (“Covered Workers”). In addition, you are required to submit vaccination and exemption status information to UNC Health for each of those Covered Workers via the web portal referenced in our letter to you. Personnel who provide in-person services to UNC Health patients, even in a patient’s home or another “offsite” setting, like a hospice or long term care facility, are considered Covered Workers.   

The COVID-19 vaccine and reporting requirements do not apply to the following individuals: 

  1. Vendor personnel who work solely in unoccupied UNC Health patient care facilities as long as they DO NOT enter any UNC Health occupied space to reach the unoccupied space (such as a plumber working on the surgical tower project). Unoccupied space means those facilities that are either totally self-contained and do not have any UNC Health patients, visitors or employees, or construction projects prior to occupation and use for UNC Health operations.  
  2. Vendor personnel that never enter the facility. Examples may include landscapers, consultants that work only on a remote basis, vendor personnel that make deliveries and/or pick up on loading dock without entering the UNC Health facility, etc.

 

May I consider and grant exemptions for my Covered Workers from the vaccine requirement?
Yes, you may consider, and grant, exemptions claimed by your Covered Workers for medical contraindications or bona fide religious reasons, as described in our letter to you. You must determine and document all exemption requests and determinations, and maintain complete records as described in the letter. Your exemption determination records are subject to review and audit by UNC Health promptly upon request. You must complete and submit the information requested via the UNC Health web portal referenced in our letter to you for each Covered Worker for whom you granted an exemption request.

 

How often must I update information via the UNC Health web portal concerning my Covered Workers?
You should visit the portal and provide updated entries whenever information concerning a Covered Worker changes. Examples may include: 

  • A Covered Worker begins or stops working or providing services at a UNC Health facility
  • A Covered Worker receives a booster dose of COVID-19 vaccine
  • There is a change in a previously granted exemption determination for a Covered Worker

 

How can I update a previously-submitted entry for a Covered Worker?

  1. Enter the portal and use the access code originally provided to the Vendor Organization 
  2. Fill out the Vendor Information page and select “yes” for the In-Person question if they qualify.
  3. On the Covered Worker Information page, fill out the Unique Identifier, Last Name, First Name of the Covered Worker.  
    • If the record is found, the Submission Status will automatically update to “Update Submission”, and the Covered Worker’s information should automatically repopulate with the information from the previous submission. 
    • To indicate that an employee no longer provides services to UNC Health, update the Submission Status to “Terminate Submission” .
    • If the remaining fields do not repopulate, complete the remaining fields in accordance with the Form Instructions. 
    • Make the necessary changes to the pertinent fields. 
  4. Ensure Attestation information is entered correctly.
  5. Submit the form. 

 

Must my Covered Workers carry proof of vaccination or exemption (e.g., vaccine cards, exemption determination letters, etc.) with them while onsite at UNC Health Facilities?
No. You must maintain records sufficient to show compliance with UNC Health’s COVID-19 vaccine requirement for your Covered Workers who visit or work in UNC Health facilities, including exemptions granted by you, as further described in our letter to you. You and your Covered Workers must provide documentation of vaccination and exemption status promptly upon request by UNC Health.

 

Who will have access to this information?
The information you submit via the UNC Health portal and any documentation you produce in response to requests by UNC Health will be securely maintained and available only to authorized UNC Health personnel and authorized Federal and State government regulatory authorities. 

 

What happens if am unable to respond to a UNC Health facility’s service need with a Covered Worker on my staff with a documented and complete COVID-19 vaccine or exemption?
Please contact the UNC Health contract manager or your contact at the applicable UNC Health facility to discuss how service needs will be met.  

 

Must my Covered Workers receive booster doses and, if so, how often?
The CMS Rule and UNC Health requirements do not require Covered Workers to receive booster doses of COVID-19 vaccine at this time, which is subject to change if there are changes in CMS or UNC Health policy. As described in our letter to you, however, you must report via the UNC Health portal if any of your Covered Workers received a booster dose. 

 

What is the deadline for submitting information via the UNC Health portal and complying with the requirements set forth in the letter?
Please submit all information requested concerning your Covered Workers via the UNC Health portal as promptly as possible. The requirements communicated in our recent letter to you support our original communication of the UNC Health policy from September, 2021, which required vendor personnel to be fully vaccinated.  These requirements remain in place and are ongoing. Our recent letter to you describes the mode of reporting the vaccination status of covered workers to UNC Health via our web portal.

 

What documentation do I need to maintain as the employer to comply with the policy with respect to my Covered Workers?
In addition to your covered workers’ unique identifier, please maintain records sufficient to show compliance with UNC Health’s COVID-19 vaccine requirement for your Covered Workers who visit or work in UNC Health facilities, including exemptions granted by the vendor. Please do not submit vaccination records or exemption requests to UNC Health unless requested to do so. 

For Covered Workers who receive a medical exemption, the CMS Rule requires you to: 

  1. Document the recognized clinical contraindications to COVID–19 vaccines which support the Covered Worker’s request for medical exemption from vaccination;
  2. Ensure that such documentation has been signed and dated by a licensed practitioner who is not the individual requesting the exemption, and who is acting within the practitioner’s scope of practice as defined by, and in accordance with, all applicable State and local laws; and
  3. Ensure that such documentation contains information specifying which of the authorized COVID–19 vaccines are clinically contraindicated for the Covered Worker, the recognized clinical reasons for the contraindications, and a statement by the authenticating practitioner recommending that the Covered Worker be exempted from UNC Health’s COVID–19 vaccination requirements based on the recognized clinical contraindications.  

For Covered Workers who receive a bona-fide religious exemption, the CMS Rule requires you to:

  1. Document the date on which the exemption was granted.
  2. Maintain up-to-date documentation of COVID-19 vaccination exemption requests, and all related documentation for each Covered Worker requesting an exemption.

 

What information must be reported via the UNC Health portal?
The information collected through the portal for each Covered Worker includes (but is not limited to) the following:

    • Vendor 
    • Authorized vendor representative name and email contact
    • Name of Covered Worker
    • Vendor’s unique identifier for Covered Worker
    • Date and manufacturer of each COVID-19 vaccine dose and booster administered
    • UNC Health facility and work area that Covered Worker visits or services
    • Level of patient contact, if any 
    • Beginning and, if applicable, ending dates of service for applicable UNC Health facilities
    • Medical contraindications or other exemptions approved – date 
    • Attestation by authorized vendor representative 

 

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