Policy

This policy outlines expectations with regards to COVID-19 immunization. Compass strongly encourages COVID-19 vaccination as a critical layer of protection for the health and safety of our clients and families we serve, and our staff, students, and volunteers who provide services and supports. Contingent upon vaccine availability and exemptions, it is the expectation that all eligible employees, staff, contractors, volunteers, and students are fully vaccinated against COVID-19.

Fully vaccinated means having received the full series of a COVID-19 vaccine or combination of COVID-19 vaccines approved by the World Health Organization (WHO) (e.g., two doses of a two-dose vaccine series, or one dose of a single-dose vaccine series); and having received the final dose of the COVID-19 vaccine at least 14 days before providing the proof
of being fully vaccinated.

Purpose

The COVID-19 pandemic continues to pose an immediate risk to the health of persons globally. The prevalence of the new variants of concern globally and within Ontario, has increased transmissibility and disease severity than previous COVID-19 virus strains.

Health and safety is paramount as we continue to confront the challenges that COVID-19 continues to pose for our community and, especially, as we enter new waves of the pandemic that is being driven by the more transmissible variants. There are vaccines currently approved in Canada that have been shown to be safe and effective against symptomatic COVID-19. Ministry of Health’s Information regarding these vaccines can be found here: https://files.ontario.ca/moh-covid-19-vaccines-fact-sheet-en-2021-02-05.pdf.

Scope

This policy applies to all employees, staff, contractors, volunteers, and students regardless of how often or how much time spent in their respective workplaces.

Procedures/Guidelines

The Chief Medical Officer of Health (CMOH) is of the opinion that there exists or there may exist an immediate risk to the health of persons anywhere in Ontario. The objectives of the CMOH’s Directive are to set out a provincially consistent approach to COVID-19 immunization policies to:

• optimize COVID-19 immunization rates in these settings;
• ensure that individuals have access to information required to make informed decisions about COVID-19 vaccination; and
• ensure that individuals not vaccinated for COVID-19 are being monitored for COVID-19 exposure to minimize the risks.

In compliance with the CMOH objectives, the directives of Public Health Sudbury & District and our
funders, the following policy on vaccination has been put in place for all employees, staff, contractors, volunteers, and students effective November 16, 2021.

All staff, contractors, volunteers, and students are required to provide:

a) Proof of full vaccination against COVID-19. Will need to complete the online COVID-19 Vaccine Declaration Form. Vaccine receipts can be accessed at https://covid19.ontariohealth.ca/; or

b) Written proof of a medical reason, provided by a physician or nurse practitioner in the extended class that sets out:

(i) a documented medical reason for not being fully vaccinated against COVID-19, and
(ii) the effective time-period for the medical reason; or

c) Written proof to support an exemption on the basis religion or creed documentation provided by a member of the clergy or spiritual leader of a restriction on the basis of a religious or creed-based belief (connected to the person’s spiritual faith and self-definition) that prevents them from taking the vaccine; or

d) Proof of completing an online training about the benefits of COVID-19 vaccination prior to declining vaccination for any reason other than a medical reason. The approved session must, at minimum address:

i. How COVID-19 vaccines work;
ii. Vaccine safety related to the development of the COVID-19 vaccines;
iii. The benefits of vaccination against COVID-19;
iv. Risks of not being vaccinated against COVID-19; and
v. Possible side effects of COVID-19 vaccination.
Where a staff, contractor, volunteer, or student does not present proof of being fully vaccinated against COVID-19 in accordance with

1(a), but instead relies upon the medical reason(s) described at paragraph
1(b) or the religious reasons described at paragraph
1(c), the employee, staff, contractor, volunteer, or student will have to

a. Submit to regular COVID-19 rapid antigen testing (point of care testing) and must receive a negative COVID-19 antigen test result within the 72-hour window immediately before accessing the worksite or other locations while on agency business.
b. Provide verification of the negative test result as outlined in Appendix A, Rapid Testing Process.

Please refer to Appendix A, Rapid Testing Process.

Sick time can be used in the event a rapid test provides a positive result. In these cases, staff are encouraged to attend a public health testing site immediately to have a PCR laboratory test completed and must report the results to HR@compassne.ca.

Implications will vary depending on employer’s risk assessment and general duty under OHSA. The policy will be applied in accordance with the Ontario Human Rights Code.

Acknowledgement that the policy may change as the status of the pandemic changes and/or legislation or public health advice changes.

New Hires

Candidates and new hires of Compass will be subject to the same policy. Compass would advise applicants early in the recruitment process (listed on the job posting requirements) of our vaccination policy requirements. To avoid potential Human Rights violations, candidates will not be asked to disclose their status during the recruitment process. Once the successful candidate has been selected, they will be presented with an offer of employment that states that they have been advised of the obligation to adhere to COVID-19 vaccination policies and protocols of Compass and the organizations that we serve and by signing, the employee agrees to adhere to our policies which may evolve or be amended over time. If the new employee has a medical or human rights exemption or declines to be vaccinated, we would provide them the accommodations as outlined within this policy.

Training

Prior to implementation, employees will be provided with training and additional resources to ensure that they are well informed and apprised to the requirements of this policy.

Confidentiality

Compass is required, pursuant to the advice of the Chief Medical Officer of Health, to collect, maintain, and disclose statistical (non-identifiable) information that includes the number of those fully vaccinated, the number of those that have provided a documented medical reason, the number of those that have completed an educational session where applicable. The Ministry of Health may make this information publicly available. No identifying information will be provided to the Ministry in relation to this policy; all statistical information will be provided in aggregate form. Any information collected will be kept secure by Human Resources. Information received via hr@compassne.ca or stored on the People Drive is only accessible to Human Resources. This information will be disposed of via confidential shredding.

Respect for Human Rights

Compass will respect an individual’s decision to remain unvaccinated on human rights grounds including medical and religious restrictions, disability, creed, or any other grounds protected by the Human Rights Code.

Medical restrictions apply when substantiated by adequate medical evidence.

Religious restrictions apply if a person has a sincerely held religious or creed-based belief (connected to the person’s spiritual faith and self-definition) that prevents them from taking the vaccine. Compass is committed to human rights accommodation up to the point of undue hardship where a person is unable to vaccinate for human rights protected reasons.

All unvaccinated staff, students, volunteers, and contractors are required to participate in regular antigen testing, regardless of whether the decision to remain unvaccinated is based on medical or human rights.

Enhanced Protective Measures

In the event of an increase in positive cases, community risk level, or if there is a positive case within a service or location, enhanced measures may be required to protect the health and safety of our clients, families, and staff. For unvaccinated staff (regardless of medical vs. other reason), additional protective measures may be implemented, with consideration given to each circumstance. This may include (but is not limited to):

Increased rapid testing frequency
Enhanced PPE
Reassignment or temporary remote work (if suitable for the nature of the service)
Modifications to the work/service/support
Temporary, unpaid leave of absence (staff may be permitted to use vacation or lieu hours)
Restricted interactions with supported individuals

Situations will be addressed on a case by case basis.

Ongoing COVID-19 Protective Measures

All Compass policies, with respect to COVID-19 protective measures, continue to apply to all vaccinated and unvaccinated individuals as outlined in the Workplace Reintegration Plan.
All staff and students must continue to comply with Compass’ policies, protocols and guidelines with respect to physical distancing, masking, screening, personal protective equipment and any other measures intended to reduce the risk of transmission of COVID-19.

Non Compliance

Employees, staff, contractors, volunteers and students who elect not to provide proof of COVID-19 vaccination per 1 above, and rely on 2, may be subject to additional requirements such as COVID-19 testing, redeployment, personal and public health protective measures, work exclusion, etc., based on assessment by the employer of various factors and in consideration of the duty to accommodate, as applicable. Employees who are in violation Compass policies, government or Public Health directives will be subject to discipline up to and including termination.

Review of Policy

This Policy will be frequently reviewed and updated to reflect current guidance, legislation and directives from the Ontario government, the federal government, Ministry of Health, the Public Health Agency of Canada, Public Health Ontario, Local Health Units and any other relevant health bodies.

Previous Approval Dates

Sept 30, 2021 (Original Date)

Vaccination