The Rhode Island Department of Health (“DOH”) has just issued guidance indicating that the vaccine mandate for healthcare employers can be delayed for 30 days to October 31, 2021. To obtain the 30-day relief, the healthcare employer must submit a COVID-19 Vaccination Corrective Action Plan. The plan due tomorrow, must include the following information – and attestations:

• The facility attests that it will achieve full compliance with the regulations no later than October 31, 2021. The Plan specifies the healthcare facility’s measures to attain full compliance, including the healthcare facility’s efforts to achieve 100% COVID-19 vaccination of all healthcare workers.
  
  
• The Plan specifies how any non-exempt, unvaccinated healthcare workers permitted to enter the healthcare facility on or after October 1, 2021 are critically necessary to the facility’s operation and/or patient care.
  
  
• The Plan also identifies approximately how many unvaccinated healthcare workers will be permitted to enter the facility on an average day and the duties to be performed.
  
  
• The Plan specifies the temporary infection protection measures that the healthcare facility will be implementing for COVID-19 unvaccinated staff who are critically necessary to the healthcare facility’s operation, and that such measures include COVID-19 testing of unvaccinated healthcare workers at least twice weekly.
  
  
• The Plan attests that healthcare workers onboarded by the facility on or after October 1, 2021 will be vaccinated against COVID-19 prior to their facility start dates.

DOH provided an email address to obtain a form plan at DOH.OFR@health.ri.gov. PLDO attorneys are available to assist our clients regarding the Plan. Please contact PLDO Principal William E. O’Gara and Partner Matthew C. Reeber at 401-824-5100 or email wogara@pldolaw.com or mreeber@pldolaw.com.


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