By now, most independent schools are very familiar with COVID-19 vaccine policies. As an integral part of their health and safety policies for the 2021-2022 school year, many independent schools acted quickly by either requiring or strongly encouraging vaccines over the summer and, as a result, ensured that the majority (if not all) of their faculty and staff were fully vaccinated before the start of the school year. With evidence that vaccinated individuals’ immunity to COVID-19 begins to wane after six months, however, schools may wonder how they can prevent their staff’s waning immunity from causing an outbreak on campus later this year.
Enter the COVID-19 vaccine booster. In September, the U.S. Food and Drug Administration (FDA) authorized a single booster shot of the Pfizer-BioNTech COVID-19 vaccine for the following groups, as long as six months have passed since their second dose:
- People age 65 and older
- People ages 18 through 64 who are at high risk of severe COVID-19 infection
- People ages 18 through 64 who are at high risk of exposure and transmission at work or in institutional settings, including school employees
On Wednesday, October 20, the FDA also authorized Moderna boosters for the above groups. At the same time, the FDA also authorized Johnson & Johnson’s Janssen vaccine booster for all individuals 18 years of age or older who originally received Johnson & Johnson’s vaccine.
Since school employees are, or will soon become, eligible for any one of the three available COVID-19 boosters in the near future, schools may consider whether it is time to update their COVID-19 vaccination policies to require employees to get their COVID-19 boosters.
For a number of reasons, it may be premature for schools to require COVID-19 boosters at this time. First, although school employees who were vaccinated last year may already be eligible to receive a COVID-19 booster, many employees who received their vaccines over the summer may not yet be able to receive a booster. Therefore, requiring the booster now may pose logistical challenges to schools seeking to ensure 100% compliance with their vaccination policies, including having to document when employees received their original vaccine and tracking when each employee becomes eligible for their vaccine booster. Furthermore, enforcing a vaccine booster policy now when only some employees are currently eligible may feel inequitable to those employees being required to receive another vaccine now, especially when such employees were among the first to cooperate with the school’s initial vaccination requirement.
In addition, the release of COVID-19 vaccine boosters has not (yet) impacted the definition of who may be considered “fully vaccinated.” According to the U.S. Centers for Disease Control and Prevention (CDC), an individual is still considered fully vaccinated when two weeks have passed since the person's second dose in a two-dose series, such as the Pfizer or Moderna vaccines, or when two weeks have passed since the person received a single-dose vaccine, such as Johnson & Johnson's Janssen vaccine. It is currently unclear when, and if, public health guidance will evolve to include a COVID-19 booster in the definition of “fully vaccinated” sometime in the future. Since schools’ health and safety policies, including their vaccine policies, rely on guidance from the federal and state public health authorities, schools may be wise to coordinate any updates to their vaccine policies with new developments in public health guidance regarding the vaccine booster.
What Can Schools Do Now to Prepare?
It is important for schools that intend to require booster shots in the future to begin planning now. To ensure the smoothest rollout possible, it is important for schools to begin communicating their intention to require booster shots in the future and to make clear their expectation that their employees will seek to receive their COVID-19 boosters when they become eligible to do so. Schools should update their policies and employment agreements for next year to align those documents with the school’s plans. As with the initial vaccinations, it may also be helpful to encourage employees to receive the booster, provide information regarding eligibility for the COVID-19 vaccine boosters, and communicate nearby locations where vaccine boosters may be available.
When it comes time to update their vaccination policies, schools should consider paying for the costs associated with getting the booster shot, including compensating employees for the time spent getting their booster shots. In addition, some states still require employers to provide paid time off to employees who experience side effects from the vaccine booster. Even if not required to do so under state law, schools should consider providing paid time off for recovery from vaccine side effects anyway.
Independent schools with questions about developments in COVID-19 vaccination policies and best practices are encouraged to contact Caryn Pass, Grace Lee, Janice Gregerson, or Ashley Sykes for assistance.