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Rhode Island Healthcare Workers Must Be Vaccinated by October 1

On August 10, 2021, Governor Dan McKee announced that Rhode Island (RI) health care workers and heath care providers must be vaccinated against COVID-19 by October 1, 2021. On October 1, 2021, healthcare facilities must deny entrance to any health care workers who are not vaccinated, subject to medical exemptions.

Healthcare Facilities. The regulation applies to healthcare facilities, which is broadly defined to include any institutional health-service provider, facility, or institution, place, building, agency or portion thereof, whether a partnership or corporation, whether public or private, whether organized for profit or not, used, operated, or engaged in providing health care services under R.I. Gen. Laws § 23-17-2(8).

Healthcare Workers and Healthcare Providers. The term healthcare worker is also broadly defined to include any person who is temporarily or permanently employed by or at, or who serves as a volunteer in, or has an employment contract, with a healthcare facility and has or may have direct contact with a patient in that facility, including those who are not directly involved in patient care such as clerical, administrative, billing, and maintenance, who may not be directly involved in patient care, but potentially exposed, in the course of employment, to infectious agents.

Healthcare provider is defined as anyone licensed by DOH to provide healthcare services, including but not limited to, a physician, dentist, nurse, optometrist, podiatrist, physical therapist, social worker, pharmacist, emergency medical service practitioner, or psychologist.

Meaning of Vaccinated. Under this rule, a person is considered “vaccinated” after receiving the final dose of the Pfizer or Moderna vaccine or a single dose of the Johnson & Johnson vaccine, as well as a person who has received all doses of any vaccine approved by the World Health Organization (WHO) (including the Astra Zeneca vaccine) and/or by the DOH (including the Novavax).

Vaccination Status. Proof of vaccination must be entered into the Rhode Island Child and Adult Immunization Registry:

  • Healthcare workers/providers who are vaccinated in RI will have this requirement done automatically.
  • Healthcare workers/providers who are not vaccinated in RI must complete the form using this link and email the completed form to RIDOH.RICAIR@health.ri.gov.

Providing copies of vaccination cards, attesting to their status, or simply using the honor system are not acceptable methods for proof of vaccination under the regulations.

Unvaccinated Workers. Unvaccinated healthcare workers at healthcare facilities falling under the scope of the Emergency Rule who are not vaccinated are required to:

  • Wear a procedure mask or higher-grade mask (e.g., KN95 or N95) while working in the facility; and
  • Be tested at least two (2) times per week for COVID-19 via any COVID-19 test authorized by the FDA.

Medical Exemptions. Healthcare workers and providers can be medically exempt from being required to be vaccinated provided that a licensed physician, physician assistant or advanced practice registered nurse signs a medical exemption stating that the healthcare worker or provider is exempt from the COVID-19 vaccine because of medical reasons, in accordance with Advisory Committee on Immunization Practices (ACIP) guidelines and determined as acceptable by the facility. Medically exempted individuals must follow the protocols for unvaccinated workers.

Masking Requirements. Healthcare facilities must provide an adequate supply of procedure or higher-grade masks to any healthcare worker at no cost.

All healthcare providers who are not working at a health care facility who are not vaccinated must wear a procedure or higher-grade mask (i.e., KN95 or N95) in the course of their employment.

Healthcare facilities should have completed any required medical evaluations and fit testing before requiring employees to wear respirators, including N95 respirators. Employers are also advised to review their respiratory protection policies to ensure that those meet all OSHA requirements for respiratory protections.

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