Q: What does my organization have to do about this year’s influenza season to satisfy Joint Commission requirements?
A: Critical Access Hospitals, Hospitals, and Long Term Care facilities have a standard specific to Healthcare Worker Influenza Vaccination Programs (See standard IC.02.04.01). Other health care settings, such as Ambulatory Care, Home Health Care, Laboratory, and Behavioral Health Care (for example, day care and residential) settings do not have specific standards; however, as part of their infection prevention and control activities these organizations need to assess their risks and take actions to protect their patients and health care workers (See standards IC.01.03.01 and IC.02.01.01).
In 2006, The Joint Commission announced a new infection control standard requiring accredited hospitals, critical access hospitals, and long term care facilities to offer influenza vaccinations to health care workers, including licensed independent practitioners and volunteers. The Joint Commission developed the standard in response to recommendations by the Centers for Disease Control and Prevention (CDC) making the reduction of influenza transmission from health care professionals to patients a top priority in the United States.
The Joint Commission standard IC.02.04.01 requires Critical Access Hospitals, Hospitals, and Long Term Care facilities to do the following:
- Establish an annual influenza vaccination program that includes, at a minimum, staff and licensed independent practitioners.
- Provide access to influenza vaccinations on site.
- Educate staff and licensed independent practitioners about influenza vaccination, non-vaccine control measures (such as hand hygiene, sneeze and cough etiquette), and the diagnosis, transmission, and potential impact of influenza.
- Annually monitor vaccination rates and reasons for nonparticipation in the organization’s immunization program.
- Implement enhancements to the program to increase participation.
Q: Does The Joint Commission require signed influenza vaccination declination forms?
A: No. The Joint Commission does not require declinations from individuals refusing influenza vaccination. For Critical Access Hospitals, Hospitals, and Long Term Care facilities, the Joint Commission does require that organizations collect and evaluate reasons health care workers do not get vaccinated in order to improve the organization’s health care worker influenza program. It does benefit ALL health care settings to understand why their health care workers do not get vaccinated in order to protect their patients, residents, or individuals served.
However, the CDC’s Interim Guidance on Infection Control Measures for 2009 H1N1 Influenza in Healthcare Settings, Including Protection of Healthcare Personnel posted on October 14, 2009, states
“To improve adherence, vaccination should be offered to healthcare personnel free of charge and during working hours. Vaccination campaigns with incentives such as lotteries with prizes should be considered. Healthcare facilities should require personnel who refuse vaccination to complete a declination form.” (http://www.cdc.gov/h1n1flu/guidelines_infection_control.htm) (Accessed 10/16/09)
The Occupational Safety and Health Administration (OSHA) will also be releasing further guidance within the next several weeks. The OSHA statement from October 14, 2009 can be accessed at http://www.osha.gov/pls/oshaweb/owadisp.show_document?p_table=NEWS_RELEASES&p_id=16602 (accessed 10/16/09).
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Q: I have a family member who tested positive for H1N1 on the PCR test. They have already had the seasonal influenza vaccine and are now recovered from H1N1. Now that this person has recovered, is it still advisable for them to get the H1N1 vaccine?
A: If they have laboratory confirmation of H1N1 influenza, CDC recommends there is no need for vaccination. Again, the important point is laboratory confirmed H1N1.
Q: How long does it take for immunity to develop post-vaccination?
A: According to the CDC, once you get vaccinated, your body makes protective antibodies in about two weeks. However, children younger than 9 years old who are being vaccinated for the first time need a second dose 4 or more weeks later in order to be protected.
CDC has stated that the ability of the seasonal flu vaccine to protect a person depends on at least two things: 1) the age and health of the person getting the vaccine, and 2) the similarity or "match" between the virus strains in the vaccine and those being spread in the community. Keep in mind that vaccine effectiveness is not 100%, and some people can still get the flu. For instance, some older people and people with certain chronic illnesses might develop less immunity than healthy young adults after vaccination. However, even for these high-risk individuals, the seasonal flu vaccine still can provide protection against getting severe complications from seasonal flu.
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Q: Is it legal to gather information about reasons for declination?
A: The Joint Commission requires in standard IC.02.04.01 that the hospital “annually evaluates vaccination rates and the reasons given for declining the influenza vaccination”. How the hospital chooses to collect that information, whether through signed declinations, staff surveys, focus groups or other means is up to the individual hospital.
However the organization chooses to collect that information, the organization should evaluate their compliance with HIPAA, state law and organizational policy. That said, there is a difference between asking for personal information and compelling people to answer personal information. Making sure that individuals are given information about why you are gathering this information, what it will be used for and giving them an option not to provide personal information is undoubtedly a good practice.
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