The Implications for Pharmacy of Mandated COVID-19 Vaccinations at Universities

Pharmacy Times® interviewed Amy Snyder, a member at Eckert Seamans Cherin & Mellott, on the implications for pharmacy of mandated COVID-19 vaccinations in higher education institutions.

Alana Hippensteele: So, Rutgers University was one of the first US universities to mandate that all 71,000 students must be vaccinated to return to campus. Now, it is common for certain employers to require immunizations for employment, but the requirement in the higher ed sphere is a much newer conversation in the country, with implications for the potential need for pharmacy involvement in order to meet the high demand among this population.

So, Amy, is there any precedent around universities requiring immunizations for all of their students?

Amy Snyder: There is. For a long time, many universities have required vaccinations. For example, measles, mumps, rubella, any meningococcal meningitis vaccinations, things of that nature. So, it's not necessarily a new topic for many students who are entering universities that they'd have to get some type of vaccination and show proof of vaccination in order to attend classes.

Alana Hippensteele: Right, right. How many universities have mandated this so far and have any shared plans for facilitating a mass vaccination of their students?

Amy Snyder: The number is actually growing. Just yesterday, I saw news articles about several colleges in Georgia who are now mandating, including Emory, several universities in New York, so it seems that each day additional universities have announced their plans to require the vaccination for the fall semester.

Alana Hippensteele:Right, and what is Rutgers doing specifically to make sure all of their students are vaccinated, and are they using medical or pharmacy faculty in order to support this process?

Amy Snyder: Right. Rutgers is requiring students to upload some information into a portal that reflects their vaccinations, and they actually have published the procedures online, so people can go in and see how that process has been initiated.

They have also announced that they are going to be an approved provider of the vaccines, but the specific plans for how that's going to be rolled out will be dependent upon how much vaccine that they actually obtain, so that information should be forthcoming.

Alana Hippensteele: Got it, got it. If a university does require vaccinations, is that university liable to provide said vaccine for students, or are students, by accepting admission to the university, legally liable to meet this requirement themselves?

Amy Snyder: There are different requirements depending upon what state universities are in, so if you check your state law, that's going to tell you what specific requirements.

For example, some states will require that a university has to require x, y, and z vaccines, and that you also have to provide y and z for students, if they can't get it elsewhere. In terms of the COVID-19 vaccine, because it is still so new, I'm not yet aware of any state laws that are requiring that this be provided on campus, if it's being required. But again, this is such a topic in development that it's important to keep on top of what your specific requirements are in each state.

Alana Hippensteele: Right, right, absolutely. For institutions requiring immunizations, will they need to acknowledge the potential for exceptions, and what might some of those exceptions be?

Amy Snyder: Yes, again, another function of state law here, but there are many states that do require exceptions. For example, for medical reasons if a student is unable to get a vaccine because of his, her, or their specific medical condition, the university is going to have to consider what type of reasonable accommodations might be available for that particular student. Likewise, some state laws do have religious exemptions as well, so that a university would have to consider if a student had a specific religious objection to getting a vaccine, what other types of accommodations, if any, are available for that.

Alana Hippensteele: Right, and what might the process be for assessing and implementing immunization exceptions at institutions like universities?

Amy Snyder: That is going to be specific to each university, but there should be a written process that's in place that communicates to a student how they can both request an exemption, how it will be considered, and how they can provide additional information.

So, it may be that they submit a doctor's note that explains their individual health circumstances; it also could be something that if they have a particular religious objection to a vaccine, that perhaps they sign an affidavit or some other type of document that explains how their religious beliefs intersect with vaccination, and why they cannot get the vaccination due to those religious beliefs.

Alana Hippensteele: Right. Outside of these recognized immunization exceptions, what might a university's response be if a student refuses to be vaccinated outside of those exceptions or even lies about being vaccinated?

Amy Snyder: Well, most universities have in place a disciplinary process, so it's possible that if you misrepresent the circumstances about having received a vaccine, that could be considered as part of the disciplinary process. So, it's important that it be explained to students that when they are offering their information about vaccination, what the school's policy is on misrepresentations of the information provided.

Alana Hippensteele: Right, right. What are some other considerations for the implementation of vaccination policies at universities?

Amy Snyder: Education about the vaccine; the importance of it. Making sure that students are aware of the reasons why a vaccine policy has been initiated—it's for the protection of all students, and studies have shown how efficient and effective these vaccines can be at preventing the spread of the virus.

So, the sooner that the population is vaccinated, the sooner that university can look towards getting rid of some of the other protective measures that have been required, [such as] masking, [so they can] perhaps get back to more normalcy with activities, increasing the number of attendants at sporting events, all the things that go along with university life that really add to the student experience.

Alana Hippensteele: Yeah, absolutely. Are the legal issues that relate to this immunization requirement at universities similar to those of other employers?

Amy Snyder: They are similar. Other employers may decide to implement certain vaccination policies, particularly in health care, at institutions of learning as well, for other types of vaccines. When those types of policies are developed, the employers also have to consider exceptions to the policies for reasons of accommodation of disabilities or of religious beliefs.

Alana Hippensteele: Right, right. What potentially may be the role of the pharmacist in the immunization of students and even faculty attending universities that mandate COVID-19 immunization?

Amy Snyder: The role of the pharmacist is potentially to obviously assist with this process. It's a really good opportunity to educate students about the importance of the vaccine, about potential side effects, and the fact that getting vaccinated is going to again get us back closer to a sense of normalcy.

There also are in the works certain technology, some pretty exciting technology in development, that's on the horizon, where you have a vaccination credential initiative, which is like a coalition of health care providers and tech companies, who are working on developing apps that would establish vaccine credentialing. So, the role of pharmacists may be to work with those new emerging technologies to get the information that the student needs to show that they are in compliance with the university's policies and procedures.

Alana Hippensteele: Right, right. Thank you so much for taking the time to speak with me today, Amy.

Amy Snyder: You're very welcome. It's my pleasure.