Vaccine Requirements: Frequently Asked Questions

Covered workers and requirements

What is the effective date of the requirement? 

As of September 27, 2021 the Executive Order requires compliance with the vaccination requirement, including meeting all documentation requirements. Programs should work with their staff immediately to achieve compliance. The Order is effective through February 15, 2021. In addition, DPH issued Implementation Guidance For Executive Order 13G to guide compliance with the Executive Order. Providers should consult the full document for detailed information. 

Which staff are “Covered Workers” under Executive Order 13G? 

“Covered Worker” refers to:

  • All employees, both full and part-time
  • Contractors
  • Providers
  • Assistants
  • Substitutes
  • Other individuals working in a public or non-public pre-K to grade 12 school or Child Care Facility, including individuals providing operational or custodial services or administrative support
  • Any person whose job duties require them to make regular or frequent visits to any such schools or child care facilities or to have regular or frequent contact with children, students, or staff. Those who make regular or frequent visits may include consultants who are present in the program on a frequent or recurring basis.  

“Covered Worker” does not include:

  • Contractors or employees of an outside vendor who visits a public or non-public pre-K through grade 12 school or Child Care Facility only to provide one-time or limited-duration repairs, services, or construction
  • Parents and volunteers
  • Household members residing in a family child care home

Leaders are encouraged to seek legal counsel if uncertainties arise regarding whether an individual(s) should be considered a covered worker(s) subject to the Order. 

Are OEC licensing inspectors required to meet the vaccine requirement?

Yes. OEC staff are State employees who must meet the requirement as of September 27, 2021. State employees must provide documentation (see proof of vaccination below) of their compliance to the state HR representative. Staff who are in the field performing inspections and delivering other services have been determined to meet the requirements in Executive Order No. 13G as verified in WellSpark COVID Navigator™, the State’s monitoring portal.

What does it mean to be “fully vaccinated?” 

 “Fully vaccinated” means at least 14 days have elapsed since a person has received the final dose of a vaccine approved for use against COVID-19 by the U.S. Food and Drug Administration, or as otherwise defined by the Centers for Disease Control. Individuals who have not achieved fully vaccinated status are required to submit to weekly testing. 

Are programs required to pay staff for the time necessary to obtain the vaccine or test? 

Programs should treat this requirement as they do other health requirements staff need to meet to maintain eligibility to work. Programs should follow their own policies with regard to how they expect staff to meet these requirements. 

Testing

How do covered workers access testing? 

Those individuals who need to be tested for COVID-19 will find information on locations at the Connecticut COVID-19 Response webpage. Testing locations are found by typing a zip code in the search box on the right side of the page.  

Payment is based on the individual’s insurance coverage or is self-pay.  Individuals should check with their insurance carrier or the testing site regarding cost and payment for testing. 

What kind of test satisfies the testing requirement? 

Covered workers who are not ‘fully vaccinated’ by September 27, 2021 must undergo testing at least weekly (at least one test every 7 days) unless they can provide documented proof that they have tested positive for, or been diagnosed with, COVID-19 in the prior 90 days. Testing must be either PCR or antigen SARS-CoV-2 tests and must be administered and reported by a state licensed clinical laboratory, pharmacy-based testing provider, or other healthcare provider facility with a current Clinical Laboratory Improvement Amendments (CLIA) waiver. Only test results submitted to the state, state hospital, school board, or child care facility within 72 hours of the test administration date will be deemed compliant with the testing requirement. Test result reports should include the name and location of the testing laboratory or provider facility performing the test, the name of the person tested, the date the sample was collected, and the test result.

Home-based testing and results obtained outside of a facility of the type indicated above are not considered adequate proof of a SARS-CoV-2 test for the purposes of complying with the Executive Order.

Are child care staff able to choose weekly testing rather than obtain a vaccine?

Only Covered Workers hired before September 27, 2021 may use testing to meet the requirements of Executive Order No. 13G without an exemption from vaccination. Covered workers hired on or after September 27, 2021 must have an approved exemption from vaccination in order to use weekly testing to comply with the vaccine mandate. 

Are child care staff able to access expedited testing?

No. There are no longer priority lines for testing of providers.

Compliance and exemptions

What documentation is required to prove vaccination and testing compliance?

To see detailed information about documentation requirements for individuals by vaccination status, this chart will help:

Operators of programs are required to have readily available for inspection either

  • Proof of vaccination status, which includes one of the 3 following:
    • (1) CDC COVID-19 Vaccination Record Card or photo of the Vaccination Record Card
    • (2) Documentation from a health care provider or electronic health care records
    • (3) State Immunization Information record. Personal attestation will not be accepted as an acceptable form of proof of a COVID-19 vaccination. 
      And
    • A signed declaration of authenticity of vaccination record. This declaration may be on the form provided by the State of CT or on a form that collects the same information and that are complete and certified by the provider as appropriate.
  • Documented proof of each weekly testing result

How does a program handle and document a medical or religious exemption? 

With respect to medical exemptions, the Order requires that a physician, physician’s assistant, or advance practice registered nurse (“APRN”) determine that the administration of a COVID-19 vaccine is detrimental to the covered worker’s health. 

With respect to religious exemptions, the Order requires that the covered worker object to vaccination on the basis of a sincerely held religious or spiritual belief. 

These exemptions must be documented on a form which gathers the information required for medical exemption or a form which gathers information required for spiritual or religious exemption. Providers may use these forms or a form of their making that gathers the same information.

A covered worker who has not demonstrated proof of full vaccination, including those with religious or medical exemptions, must undergo COVID-19 testing one time per week on an ongoing basis.  

If a child care provider has documented an exemption to the vaccine requirement, do they need to meet the COVID-19 testing requirement?

If the covered worker was hired before September 27, 2021 and regardless of whether the individual has a medical or religious exemption, the individual meets the requirement if they are in compliance with the weekly testing requirement. 

If the covered worker is hired on or after September 27, 2021 and has been granted an exemption from vaccination on the basis of a medical condition or firmly held religious or spiritual belief, the individual must comply with the foregoing testing requirements.

What happens if Covered Workers do not comply with the Executive Order?  

Programs should follow their own policies with regard to how they will address individuals’ refusal to comply with the vaccine requirement, as they would with any other violation of program policy. If, however, a covered worker refuses to obtain a vaccine or receive weekly testing, or falls out of compliance at any time with the order, that worker’s access to the facility shall be restricted. Further consequences for a covered worker’s refusal to receive weekly testing are to be determined by the program and its legal counsel. 

OEC will monitor licensed program’s compliance with the Executive Order during licensing visits similarly to how the agency currently monitors health records. Depending on the number of staff, this may include a sampling of records. Programs shall maintain on site or have readily available during inspection, verification of compliance with the vaccine requirement for each covered worker. Instances of noncompliance with the vaccine requirement will be cited and programs will be asked to submit a corrective action plan addressing the violation. Individuals not in compliance with the requirement will not be allowed on the premises of a licensed child care facility until compliance with the vaccine requirement is met. Licensed child care facilities will be subject to disciplinary action including civil penalty, or suspension or revocation of a license if a violation is not corrected.

How does a program manage documentation of contractors who are required to meet the Executive Order but are not employed by the child care facility?

Child care facilities are responsible to secure compliance reports from contractors regarding their contract workers’ compliance with the Executive Order. At a minimum, periodic reporting of numbers of contract workers who are vaccinated, have been granted an exemption, and are subject to weekly testing should be reported to the child care facility at a frequency that the child care facility determines is sufficient to assure compliance. Child care facilities must require contractors to positively affirm that contract workers and their Contractors are in compliance with the provisions of the Executive Order prior to granting those workers access to their facilities.

Last updated October 12, 2021