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Local health departments will enforce health care workers' compliance with state's COVID-19 vaccination, testing mandates

With FDA's full approval of Pfizer vaccine, dental offices may consider imposing vaccination mandates

August 25, 2021 7430

Dental offices in California should be complying now with the state public health order of July 26 that requires all health care workers, beginning Aug. 23, to either be fully vaccinated against COVID-19 or submit to regular testing. 

The state order mandates weekly testing for unvaccinated dentists and dental staff. Employees who are exempt from the vaccination mandate for qualifying medical reasons and sincerely held religious beliefs will still need to be tested weekly, as CDA’s FAQ about the state order explains.  

Vaccination will soon be mandated in San Francisco, Los Angeles

Updated in 2021 and 2022 to include reference to Berkeley and Santa Clara health orders.

Dental offices in San Francisco and Los Angeles counties will soon be required to comply with local public health orders that mandate COVID-19 vaccination. Weekly testing will no longer be an option for dental professionals in those regions unless the employee is legally exempt from vaccination. 

Other cities and counties, as well as private employers, may implement vaccination mandates in the coming weeks and months, especially following the FDA’s full approval of the Pfizer-BioNTech vaccine on Monday. The Berkeley City Health Officer on Sept. 1 issued an order that requires dental-office employees and certain other employees to either be fully vaccinated against COVID-19 or provide weekly proof of a negative COVID-19 test to enter their employment facility beginning Oct. 15. And Santa Clara on Dec. 28, 2021, issued a health order requiring vaccination in high risk settings, including dental offices, by Jan. 24, 2022. Individuals may be exempt if they have an approved medical or religious exemption and comply with any specified minimum requirements of the respective order.

Dental offices  must comply with the state public health order prior to the effective date of their respective local order.

Employers must record employees’ vaccination status, weekly testing results

Local health jurisdictions will enforce compliance with the state's July 26 order and will also receive complaints about noncompliance.

Dentist employers must track their employees’ COVID-19 vaccination status or weekly test results and provide them to their local health department for case investigation if requested.

The state order does not specify how employers should track the results. CDA provides members with templates for recording vaccination status and weekly testing results, which the employer and employee can sign and date. The vaccination tracking form can be used in conjunction with the self-certification of the employee vaccination form. These documents must be stored confidentially and separately from employees’ personnel files.

Related update: Gov. Gavin Newsom on Oct. 8 signed CDA-supported legislation that permits California dentists to apply for the requisite laboratory licensure to administer rapid COVID-19 tests in the dental office. Read the CDA article for details and a link to CDA's updated COVID-19 Laboratory Testing Toolkit.

Pfizer-BioNTech COVID-19 vaccine gains FDA’s full approval 

The Food and Drug Administration on Aug. 23 granted full approval to the Pfizer-BioNTech COVID-19 vaccine for individuals ages 16 and older, making it the first COVID-19 vaccine to win such approval.

The FDA’s news release describes in detail the additional effectiveness data the agency reviewed to support its decision. The drug will now be marketed as Comirnaty and will still be available under the emergency use authorization for individuals ages 12 to 15.

With the vaccine’s full approval, public and private employers across California and the U.S. may feel more confident about mandating vaccination for their employees. Dental offices are among them, particularly if compliance with the weekly testing mandate proves to be burdensome and costly for the practice.

CDA resources assist compliance with vaccination mandates

In accordance with the Equal Opportunity Commission and the California Department of Fair Employment and Housing, employers can require their employees to receive the COVID-19 vaccine as part of the employer’s health and safety program to prevent COVID-19 in the workplace.

Dentist employers who choose to mandate COVID-19 vaccination in counties that have not yet implemented local public orders requiring vaccination can use CDA Practice Support’s sample Mandatory COVID-19 Vaccination Policy, which complies with all applicable laws and is based on CDC and state guidance. They will also need to record their employees’ vaccination status and can do so with the aforementioned vaccination tracking and self-certification of employee vaccination forms.   

Ensuring patients’ confidence about infection-control practices

Dentistry already has an outstanding record with infection-control practices long required by Cal/OSHA, the Dental Board of California and other governing bodies to keep patients and staff safe.

Dental offices should be ready to address patients’ questions and concerns about their safety and may want to assure patients in advance of their appointments that the dental office follows rigorous infection-control protocols.

CDA resources will assist dentists with patient communications and include template letters and emails, in-office flyers and messages that dental offices can post on their websites and social media pages. CDA also offers tips for welcoming patients into the office and communicating face mask requirements and other protocols in place for patients’ safety.

Face masks are still required by Cal/OSHA in dental offices, regardless of vaccination status. Infection-control protocols remain critical as infections and hospitalizations, driven primarily by the COVID-19 delta variant, are increasing in most regions of the state, especially in areas with low vaccination rates.

Vaccination rates will naturally be low in pediatric dental offices because a COVID-19 vaccine is not yet approved for children under age 12.   

Patient flyers, wearable buttons available through the vaccination initiative

California dentists are vaccinated against COVID-19 at a much higher rate than adults nationwide, according to a recent CDA-CDPH survey. Dentists are positioned daily to discuss the safety and efficacy of the COVID-19 vaccines with their patients and the public. CDA’s Vaccine Confidence Toolkit includes talking points and other resources to help dentists have those conversations easily.  

Although state law prohibits employers from disclosing employees’ vaccination status, dentists and staff can also choose to voluntarily wear “I’m vaccinated” buttons that CDA members can order through a joint initiative of CDA and CDPH. Through the initiative, dentists can also download fact sheets for patients and other resources to promote vaccine awareness and confidence in the dental office.

CDA advocating for clarification on testing requirements 

CDA is continuing to push state officials to provide clarification on how the state’s weekly testing mandate will be paid for, including employees’ time for testing. Watch the newsroom and read CDA’s weekly newsletter for more of the latest information. 

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