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Mel Gravely
May-11-2021

Putting together a COVID-19 vaccine policy for your Head Start program

head start covid vaccine

As of the writing of this blog, approximately 44% of Americans 18 and over have been fully vaccinated against COVID-19 with one of the three approved vaccines, with an additional 20% say they plan on getting it soon. So what about the other 30-40%? For the past few weeks, vaccine rates have been slowing down. Experts say that vaccine hesitancy could be a real challenge in the race to get “back to normal.”

Based on the statistics, it’s likely that your Head Start program will face at least some amount of vaccine hesitancy, whether by staff, volunteers, parents, or partners. The question is, what to do about it? Obviously keeping everyone who enters a Head Start facility safe is a top priority. It’s likely that your Head Start program will need to come up with some sort of written policy that spells out your expectations for those entering your building on a regular basis.

Before COVID-19 descended on the world, we wrote a post about vaccination requirements for Head Start. This post primarily focused on vaccination requirements for children who attend your program. In it, we wrote that the Head Start program does not have national guidelines for vaccinations, but rather defers to state law in which a program is located.

Some states such as California do have laws that require pre-school teachers and staff to be vaccinated against certain types of diseases such as measles and pertussis. While no laws currently exist on the books for COVID-19, if the disease continues to spread and mutate in the future, such laws may come about, most likely at the state level. While Head Start at the federal level recommends the COVID vaccine for staff, there is no indication that it will (or even has the authority to) mandate it.

Can Head Start designees require employees to be vaccinated?

The short answer is yes. An employer can require employees to be vaccinated as long as that requirement does not interfere with other laws. So really the short answer is yes, but it’s complicated. The vast majority of US employees are employed “at-will,” which means an employer does not need cause to fire an employee as long as their reasons are legal (i.e. not discriminatory against an explicitly protected group). An unvaccinated person in general is not a protected class of individual. However, if that person is claiming a religious exemption or a disability that prevents them from getting vaccinated, that’s where things can get a little murky.

We’re not attorneys and don’t want to give out legal advice, so we advise that you educate yourself with some basic knowledge about the legal argument for vaccine requirements and then consult with a professional legal expert before you put any employment policy in writing that may require COVID-19 vaccination.

In our opinion, when it comes to vaccinations, it may be more beneficial to use a carrot, instead of a stick.

Incentivizing vaccination

If the legal unknowns of putting together a formal vaccination requirement give you cold feet, you might decide that it’s easier to ENCOURAGE vaccination amongst your employees rather than to MANDATE it.

For example, some incentives to encourage vaccination amongst your employees may include:

  1. Guaranteed paid time off to get vaccinated and recover from any side effects.
  2. A small stipend or bonus to get vaccinated.
  3. Making it as convenient as possible, such as administering vaccines directly at the workplace.
  4. Making it “fun.” Something as simple as a staff party after everyone is vaccinated could help boost morale and give team members something to look forward to.

What about volunteers?

As for volunteers, it’s much easier to require them to be vaccinated, since it’s not an employer-employee relationship. Our best advice here is if you do decide to require a COVID vaccination for your volunteers, make sure to be tactful about it.

  1. Communicate your policy clearly and up front with potential volunteers.
  2. Explain why you are requiring it and be prepared with something in writing to hand out.
  3. Spend time to answer questions and address any concerns that they might have.
  4. Be prepared to provide them with the resources to get vaccinated, such as directing them where to schedule an appointment, and helping to address any transportation or work schedule issues.

What about vaccinating kids?

The honest answer is we don’t yet know when (or if at all) children of Head Start age will be eligible for vaccination. Federal authorization to administer the Pfizer vaccine to children as young as 12 was just announced. Clinical trials are currently underway for younger children, but results for those aren’t expected for a while. The good news is that COVID-19 doesn’t seem to affect very young children in the same way as adults, and they don’t seem to spread the disease as readily as older children and adults do.

No matter what, your policy will have to be flexible. The COVID-19 pandemic has been a moving target since the beginning, and guidelines are continuously being updated as new science becomes available. Vaccinating children is a good example of that. As clinical trials are completed and the safety and efficacy of the vaccines in children is determined, you will need to be ready to edit and release your program’s policy to parents as soon as possible.

Head Start programs are not the only organizations that are grappling with these complicated questions. Businesses and non-profits across the country are likely gauging how far they want to go in requiring vaccines of their employees. Our best advice at this moment is, whatever you decide, be sure to communicate policies clearly, engage with legal experts as necessary, and be flexible as new science and data emerges.

As for The Gravely Group team, we were all eager to get vaccinated and feel confident in our decisions to do so. We hope to be able to see you all in person soon!

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