An update from Alan Levine regarding the federal COVID-19 vaccine mandate

COVID-19

Note: This message was emailed to all Ballad Health team members on Thursday, Nov. 11.

Dear colleagues,

As we all learned last week, pursuant to orders from President Joe Biden, the United States Centers for Medicare and Medicaid Services (CMS) has released a new rule requiring that hospitals and other health care organizations which participate in Medicare and Medicaid require their physicians, team members, volunteers, students, interns, vendors and any other individual who may come into contact with other individuals within the work setting to become vaccinated by one of the approved COVID-19 vaccines.

This means, beginning Jan. 4, all Ballad Health team members must be fully vaccinated, unless you have an approved medical or religious exemption.

This new rule is far-reaching and the implications are very serious for hospitals and health systems.  Non-compliance by hospitals will lead to significant fines and, ultimately, termination from federal health care programs like Medicare and Medicaid. Given that rural health systems like Ballad Health rely so heavily on participating in Medicare, Medicaid and other government programs (more than 70% of our patients are those who depend on government insurance), the consequences for noncompliance would be devastating to our region.

And while companies with 100 or more employees will have the ability to let their employees take a weekly test in lieu of the vaccine, this option was explicitly rejected by CMS and does not apply to healthcare organizations that receive federal dollars for Medicare and Medicaid. Healthcare facilities are being held to a higher standard because of our critical role in ensuring the health and safety of patients.

In addition to Ballad Health’s 15,000 team members and contracted vendor partners, this new rule will apply to approximately 76,000 medical providers and 17 million healthcare workers across the country.

Personally, I’ve made my opinion known on this topic for a while. I have strongly advocated that people choose to be vaccinated, and we – Ballad Health – have leaned heavily into educating people on the reasons why choosing to vaccinate is the best decision each can make. Ballad Health clinical leadership has done extensive work evaluating the evidence surrounding the vaccines, and they have been found to be safe and effective at preventing serious illness caused by the novel coronavirus (COVID-19). As evidence of the medical community’s confidence in the vaccine, more than 95% of Ballad Health physicians and providers are fully vaccinated.

While I support each person choosing to be vaccinated, I also believe vaccination is a very personal decision. As I testified to before the United States Congress just a couple of weeks ago, I have raised serious concerns that a mandate such as the one imposed on us by the Biden administration will be highly disruptive to staffing, particularly in rural communities. I do believe there are very real cultural reasons why certain populations have concerns, and my preference would be to continue educating people, while encouraging them to make the choice for themselves.

However, I am not the President, nor do I run CMS.  So my opinion is just that. … my opinion. The fiduciary responsibility of our Board of Directors and management team is to protect the public’s access to their hospitals, and to ensure we comply with federal law and the rules which apply to our participation in federal programs.  Our Code of Conduct is clear on the matter, and deliberate non-compliance is not an option. I know that many have asked that we “fight this.” As it stands, I have done more than any other health system CEO to oppose this sweeping federal mandate, up to and including testifying before the United States Congress. While some may be disappointed we will not do more to fight this rule, suffice it to say our opinion has been shared and heard. The ranking member of the House Energy and Commerce Committee Subcommittee on Health posted a statement on his website highlighting my testimony. At the bottom of this link, you can watch my comments related to the mandate, and the cultural challenges related to mandates.

With input from our regional Ethics Committee, we have established a new Mandatory COVID-19 Vaccine Policy and in accordance with the CMS mandate, medical or religious exemptions will be the only way for a team member to opt out of vaccination. Team members can access the exemption request form on the Human Resources page of the Ballad Health Intranet. All forms and any requested documentation must be returned by 4 p.m. on Wednesday, Nov. 24. Ballad Health will endeavor to evaluate these requests by Wednesday, Dec. 1. Following this review, Team Member Health will email team members to let them know whether their exemption request has been approved.

Based on the timeline issued by the federal government, team members wanting to receive the Pfizer or Moderna vaccine must receive their first dose by 6 p.m. on Dec. 5 at the latest. The single-dose Johnson & Johnson vaccine is also an option and must be received by 6 p.m. on Dec. 5 as well.

We will once again open our vaccination POD (points of distribution) centers to increase access to the vaccine for team members. More details about POD locations and schedules, as well as general information about the COVID-19 vaccine, will be shared in Ballad Health News and on Ballad Teams, our internal team member mobile app.

If you have questions about the safety and efficacy of the COVID-19 vaccine, I encourage you to email the Corporate Emergency Operations Center (CEOC) at CEOC-Vaccines@balladhealth.org and a member of the clinical executive team will ensure you have credible information to help you make an informed decision.

We have already received some questions from team members regarding whether a woman who is pregnant will have the option of deferring this requirement. The answer is yes. A woman who is in active pregnancy may request a deferral citing a medical condition after consulting with her OB/GYN and receiving concurrence from her doctor that deferring the vaccine is in her best interest. This having been said, I urge each of you to consider that the American College of Obstetricians and Gynecologists (ACOG) and the Society for Maternal Fetal Medicine (SMFM), the two leading organizations representing specialists in obstetric care, have both recommended that pregnant women get the vaccine. The Centers for Disease Control and Prevention (CDC) has also recently updated its guidelines to recommend vaccination for pregnant and breastfeeding mothers.

Pregnant and recently pregnant women are more likely to get severely ill with COVID-19 compared to non-pregnant women. According to the CDC, the evidence and data suggest the benefits of receiving a COVID-19 vaccine outweigh any known or potential risks of vaccination during pregnancy. Additionally, there is currently no evidence that any vaccines, including COVID-19 vaccines, cause fertility problems in women or men.

With a workforce that is made up, in large part, of people of childbearing age, I respect your right to make an informed decision and encourage you to speak with your personal medical provider directly. Your medical team can advise you more fully about potential benefits and risks to you and your family, based on your personal health risks, exposures to the virus that causes COVID-19 and your preferences.

It is my sincere prayer that all team members will choose to continue working with Ballad Health to serve our communities. We are grateful for the care, commitment and compassion you have shown our patients since the start of this pandemic and every day you’re on the job. However, we understand only you can make this personal choice for yourself and your family.

As always, thank you for all you do to serve our communities.

God bless,

Alan