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Vaccine Tracking: Proceed with caution



Employers are anxious for their workers to be vaccinated and return to the workplace, as questions remain as to how they can track who has been vaccinated, whether they should track such information and how they should use it if they do.

"There are a lot of questions about tracking software," says Dr. Neal Mills, Portland, Oregon-based Chief Medical Officer at
Aon PLC. "Employers need to be careful about how they will request this information and what to do with the information when they have it."

A study released in late February by Arlington, Virginia-based Eagle. Hill Consulting LLC found that 42% of U.S. workers surveyed said their employers should wait to reopen jobs until the COVID-1

9 vaccines are widely available, and 52% said their employers should require workers to be vaccinated.

The knowledge workers in the workplace are vaccinated can "provide some assurance about the safety of the environment," said Jennifer Santiago, Vice President and Risk Officer at Pennsylvania State University.

In February, Sedgwick Claims Management Services Inc. launched a vaccination tracking program that enables employers to collect employee data on a voluntary basis with a cloud-based tool. The information gathered includes whether a worker has been vaccinated, whether a second dose is needed and whether a worker experienced side effects, says Kimberly George, Chicago-based global head of product development and innovation at Sedgwick.

and monitor the safety of their employees, she said.

Employees can acknowledge if they have been vaccinated, with the understanding that the information will be shared with their employer. The tool also allows employers to request and register proof of vaccination, which some companies require before paying any offered vaccination incentives, George said.

The risk management software company Origami Risk LLC released a vaccination tracking program that includes tracking for positive COVID-19 test results. It also keeps track of the number of vaccine doses an employee has received and the dosing schedule, and generates reminders to keep employees on track for full vaccination, says Ellen Moser, Atlanta-based senior client manager at Origami.

"Having statistics at hand is the key, being able to see the proportion of people who are vaccinated," Moser said.

To date, the industries most interested in tracking vaccinations include health care systems, geriatric care facilities, food service distributors for the hospital and geriatric care sector, and health care linen and uniform laundry services, she said.

Ms. George said Sedgwick has found that employers in retail, transport, manufacturing and education are most interested in tracking vaccinations.

Before tracking vaccinations, employers should consider obstacles to the strategic collection of information, says Dr. Jonathan Weiner, Professor of Health Policy Management and Health Informatics at the Johns Hopkins Bloomberg School of Public Health.

An employer can not access an employee's records "unless we give permission or if we do not do things in an aggregated manner that follows (Health Insurance Portability and Accountability Act)", says Dr. Weiner.

Employers must also ensure that they do not care about anti-discrimination laws if they question workers who choose not to be vaccinated as to why they have declined, says Dr Mills of Aon.

Is the information collected "a verbal, anonymous, or employee-specific survey conducted to track an incentive … or is it really a return to work?" he asked.

If employers ask for proof of vaccination, they must decide how to store the information, says Dr. Mills. "That information must be kept in a separate place from the employee's personnel file, and additional confidentiality laws apply," he said.

And given the large number of vaccine distributors – as well as several different vaccines – how can an employer be sure that the "evidence" of vaccination from a worker is legitimate? he said.

Regardless of what tracking mechanism an employer uses, with only about 15% of the U.S. population fully vaccinated in March, employers must maintain coronavirus safety protocols, says Dr. John Howard, director of the National Institute for Occupational Safety and Health.

"During this transition period, a small percentage of Americans are vaccinated, but the vast majority are not," he said. "We are certainly not in that phase when we can make many big changes (in the workplace)."

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