Conversations Blog

CDPHE Vaccine Waiver Form

We now have it.  CDPHE has posted the new Mandatory Vaccination Application Waiver Form to their blog and sent it out through the COHFI system.  They want facilities to submit it directly to a special submission email,  covid_waivers@state.co.us.  After reviewing the Form, there are a couple of items of note.

• The waiver application is ONLY to be submitted if you have religious exemptions.
• They include a disclaimer that they are not evaluating the validity of your religious exemptions, and they are not requesting to see these documents with the application.
• You are still required to post the 30-day public notice, according to the usual Waiver Process.  [This linked document describes in detail what they want on the notice and where you are to post it.] You are NOT supposed to submit the application until you’ve completed this 30-day notice period.
• Under Question #4 on the application, you are to provide your percentage of vaccinated employees, direct contractors, and support staff.  Given that they expressly state in their memo that “Medical exemptions are included in the facility’s 100% vaccination status,” I would include them in the denominator (total number of people) and the numerator (total vaccinated) as you calculate the percentage.
• Under Question #6, you are to describe your efforts to comply with the regulation.  This could include the same information you have on your Ongoing Vaccination Plan, such as providing education, printed literature, individual counsel, consultation with the Medical Director, monetary incentives, paid time off to acquire vaccination, on-site vaccination clinics, reduced testing requirements upon vaccination, etc.
• Question #7 asks your proposed alternative to meeting the requirements of the regulation.  You would explain your infection control practices for unvaccinated employees, direct contractors, and support staff described in your policy, including required testing, social distancing, and PPE (under procedure #6, if you are using the draft P&P template I have provided for you).  You may also wish to include the expectation that you will enforce vaccination for newly hired personnel (under procedure #2 on my template).
• It may be tempting under Question #8 to describe how loss of personnel would adversely effect your residents rather than answering how noncompliance with the regulation will not adversely effect their welfare.  They are asking you to describe how your infection control practices for unvaccinated individuals will mitigate risk to the residents.  This question seems redundant, but I expect they are required to include it due to how the regulation for waivers is written.
• Question #9 is asking essentially for your full policy for compliance with the vaccine mandate.  You are required to copy and paste it into the document.