September 27th, 2021

COVID “What’s Next” Frequently Asked Questions

Q: The FFCRA is ending; what does that mean for my practice?

A: The FFCRA, or Families First Coronavirus Response Act, allowed for paid time off and emergency family medical leave for team members that have been affected by COVID-19. The law was extended late last year, but the pay requirements have been optional for most of 2021. The expiration of this law means that the reimbursement tax credits that have been paying companies back for the COVID-related wage losses will be ending. Hospitals will not be required to provide paid time off for team members who contract COVID (or their families). Practices can choose to offer paid time for these team members, but the wages paid will not be reimbursed by the federal government after October 1, 2021.

Q: The federal government just announced vaccine mandates; how does that affect my team?

A: The federal vaccine mandate was created for federal agencies and employers with over 100 employees. Most private hospitals have far fewer than 100 employees. If your hospital has less than 100 team members, this mandate will have zero effect on you and your practice team. If your hospital has more than 100 employees, there will be guidance from OSHA for how the vaccine mandate will affect you in November.

Keep in mind that the federal vaccine mandate may also require employers with more than 100 employees to provide paid time for employees to get vaccinated and paid time off for employees who feel “under the weather” after their vaccines. Again, keep an eye on OSHA’s website for Emergency Temporary Standards regarding these guidelines for an employer with 100 or more employees.  **NOTE: Any standards released for employers with more than 100 employees WILL include multi-location practices whose employees total 100 or more between all locations!

Q: Can I mandate vaccines for my team even if the federal mandate does not cover me?

A: Hospitals can mandate vaccines for their teams.  Vaccine mandates typically have to allow for religious and health-related exemptions. Here is a sample policy that you can customize for your practice, and here are vaccine exemption request forms that you can use for team members who want an exemption from vaccination. Remember that “reasonable accommodation,” as required by the Americans with Disabilities Act, does not necessarily mean that you must allow an exemption. If an unvaccinated employee is placing the rest of your team at an unreasonable amount of risk, you can decline the accommodation. This document outlines the steps you should take if an employee requests an accommodation.

For disability exemptions, remember that no known medical conditions absolutely prevent an individual from getting vaccinated. However, employees can be exempt due to known severe allergies to vaccine components. In these situations, you can require a note from their medical provider that explains why this employee cannot be vaccinated.

Religious exemptions are trickier, as there is little way to determine whether a team member truly holds a “sincere” religious belief. There are no major religions in the United States that discourage vaccines. Still, the constitution’s first amendment doesn’t state that people must follow a major religion to protect their religious preferences. Suppose a team member requests a religious exemption. In that case, a conversation should be had with the individual to determine whether the person actually holds that religious belief to the best extent possible. One key question that can be asked is, “have you or your family been vaccinated for other ailments” (a common requirement for schools in many areas). If the answer is yes, it is unlikely that it is truly a “sincerely held” religious belief. If you have any doubts, please consult with an employment attorney.

Research shows that vaccine mandates work. This site lists the results of several companies that enacted vaccine mandates and saw their unvaccinated population plummet within weeks.

Q: Are there currently any safety concerns I should be addressing with my team?

A: Yes! Be sure that you continue to follow any federal, state, and local guidance for masking, social distancing, curbside service, and other COVID-related changes to regular business. Be sure that you continue to hold safety meetings to reiterate the importance of masking and distancing in the hospital. Continued training to keep team exposure low in the hospital is also crucial. We recommend the COVID-19 Safety Basics course in the hub for team reminder training.

Q: How should I discuss vaccines with my team?

A: There is much animosity between those who are pro- and anti-vaccine. We have created this document to help you discuss the importance of vaccines with your team.

Q: With the Delta variant causing so much illness, should we reopen or continue curbside service?

A: This is a highly personal decision that each hospital must make. Some of the variables that should be considered are:

  • Current transmission rates in your area and state
  • The current vaccination rate of your team and your area’s population

If you decide to reopen, it should be done carefully to ensure the team can handle the inevitable changes and hiccups. This document walks you through a carefully phased reopening of your practice.

Keep in mind that there is no requirement to reopen your practice to clients. Curbside service is still a viable and, in many cases, a popular option for clients. Your primary concern should be keeping your team safe and comfortable in your practice! Employees who do not feel safe are more likely to quit, and they are more likely to file an OSHA complaint.

Q: Should I be concerned about Emergency Temporary Standards?

A: Emergency Temporary Standards, or ETS, are currently in effect in several states. These include:

  • California
  • Illinois
  • Kentucky
  • Michigan
  • Minnesota
  • Nevada
  • New Jersey
  • New York
  • Oregon
  • Pennsylvania
  • Rhode Island
  • Virginia
  • Washington State

This site links to each state’s ETS rules and guidelines. If your practice is located in one of these states, we recommend thoroughly reading your state’s regulations and guidelines and ensuring compliance.

Q: How do I help my team feel comfortable taking time off when they are sick when I don’t have the ability to pay them to be off.

A: Team members who do not have paid time off may struggle to pay the bills if they must take unpaid time off due to COVID or COVID-related issues. We recommend offering at least some paid time off for those who get their vaccines, need to recover from their vaccines, or contract (or live with someone infected with) COVID. We do understand that not all hospitals have this option available to them for financial reasons. Here are some other options available to hospitals in these circumstances:

  • Unpaid approved PTO: If you cannot provide paid time off for your team, encourage them to take time off if they are sick or exposed by offering “no questions asked” unpaid, approved time off. While this will not help the team member financially, it can take some of the burdens of guilt off of them to ensure they take the rest they need to prevent spreading the virus to other team members.
  • Short-term disability policies and AFLAC policies: Some short-term disability insurance and some AFLAC plans offer to pay for time off due to COVID and COVID-related injuries. AFLAC plans will also help pay for medical bills associated with COVID infections. We recommend looking into these policies immediately, as they may offer a low-cost option to help your team get through potential infections and breakthrough infections.

Q: Are there any other things I should be considering right now?

A: Yes! We are heading into our second holiday season with COVID still ever-present. As a result, there will be much emotional baggage that both your team and clients will be dealing with. This may include:

  • Yet another holiday away from loved ones
  • The first or second holiday season after a loved one (or more than one loved one) has passed
  • Individuals struggling financially due to income loss during the pandemic (may result in team member stress and clients unable to pay for care for their pets)
  • Pent up frustration from a “lost year” of fun, travel, gatherings, and general normalcy

While there is little that you, as a practice owner or manager, can do about these circumstances, you can modulate your response to team member and client situations to show as much compassion and empathy as possible. We recommend researching resources that might be available in your area (such as grief counselors, pet and human food banks, stress relief options, etc.) that you can offer to team members and clients who may need this assistance. Be cautious when you offer these resources, be sure that you are offering them in the proper context and not pushing boundaries.