KARE COVID-Vaccination and Exemption Policy

I. Purpose

Due to federal mandates for COVID-19 vaccination in effect and the different impacts that they may have on both communities and Heroes that utilize KARE, we are establishing a policy to provide transparency and flexibility. While the status of these rules is still in flux, KARE has created functionality that allows you to be compliant when or if these rules go into effect. By including the following processes with product features, we are enabling our community customers to set shift requirements that better reflect their own corporate policies to comply with these mandates.

II. Background

COVID Vaccination Mandates

The Centers for Medicare & Medicaid Services (CMS) issued a rule requiring mandatory COVID-19 vaccinations for healthcare workers in settings that participate in the Medicare and Medicaid programs. KARE customers vary in whether they participate in Medicare and Medicaid programs. To support the vaccination and reporting requirements, KARE provides a way to capture COVID vaccination status per HERO (healthcare worker) and provide the community a way to validate this status.

COVID Vaccination Exemption

The mandate states that any federal protection for medical needs (protected by the American Disabilities Act “ADA”) or for religious conviction (protected by Equal Employment Opportunity Commission “EEOC”) should continue to be upheld. Thus, health care facilities can allow for exemptions to staff with recognized medical conditions or religious beliefs, observances, or practices. Facilities must establish a process for staff to request either exemption and ensure that the requests are appropriately documented and evaluated. In instances of medical exemption requests, providers must ensure that all documentation confirming recognized clinical contraindications are signed and dated by a licensed practitioner other than the individual requesting the exemption.

Company Policy

Additionally, certain KARE customers have established their own policies around COVID vaccination requirements or exemption exceptions that would apply or be even more strict than the governmental standards listed above. This policy and KARE’s COVID features will allow communities to enforce whichever policy they choose.

III. KARE Policies

In order to support communities in their effort to comply with the mandate, KARE will do the following:

KARE Communities

1. Allow Communities to select whether a posted shift requires a HERO (caregiver) with a COVID-19 vaccination
   1. In addition, a Community-level setting can be enabled to apply the COVID-19 vaccination requirement for all shifts by default
   2. In addition, a Community-level lock can be enabled to apply the COVID-19 vaccination requirement for all shifts and not allow for per-shift changes
2. Allow Communities to select whether they will allow Heroes with COVID-Exemptions to work shifts that require COVID-vaccinations
   1. This forces a shift to only allow Heroes that have documentation of their COVID-vaccination status or COVID-Exemption.
3. Provide clear indications to the KARE community user whether a HERO applicant has a COVID-Vaccination card
4. Provide a way for the KARE community user to review the HERO applicant’s documentation of their COVID-Vaccination card or COVID-Exemption
5. Provide a reminder confirmation for the KARE community user when they approve a HERO
   1. If the HERO has the COVID-Vaccination card, pop-up a confirmation that the KARE Community user must review the document
   2. If the HERO has the COVID-Exemption, pop-up a confirmation that the KARE community user is aware that the HERO has an exemption and the community user reviewed the document and will ensure that, if they accept the HERO, that the community will enforce testing and protection guidelines as established by the CDC, OSHA, or any local or national government body.

KARE Heroes

1. Allow Heroes to upload a COVID-Vaccination Card document or image into KARE
   1. This will prompt a document review by the KARE Support staff to review the COVID-Vaccination Card authenticity
   2. Heroes with COVID-Vaccination cards can apply for any shift in KARE
2. Allow Heroes to upload a Medical Exemption document
   1. This will prompt a document review by the KARE Support staff to review the Medical Exemption authenticity. ONLY MEDICAL EXEMPTIONS THAT ARE SIGNED AND DATED BY A LICENSED MEDICAL PRACTITIONER OTHER THAN THE APPLICANT ARE ACCEPTABLE. Download the form.
   2. Heroes with Medical Exemption documentation can only apply for shifts that allow for COVID-Exemptions or that do not require COVID-vaccinations
3. Allow Heroes to upload a Religious Exemption document
   1. This will prompt a document review by the KARE Support staff to review the Religious Exemption authenticity. ONLY KARE BRANDED EXEMPTION DOCUMENTS WILL BE ALLOWABLE FOR RELIGIOUS EXEMPTIONS. Download the form.
   2. Heroes with Religious Exemption documentation can only apply for shifts that allow for COVID-Exemptions or that do not require COVID-vaccinations
4. Provide clear indications to the HERO whether a shift requires a COVID-Vaccination, COVID-Exemption, or nothing on the shift in the KARE Heroes mobile app.
   1. Restrict the HERO to only apply for shifts in which they meet the COVID documentation criteria