Position Statement: Mandatory Influenza Immunization of Healthcare Workers

The Centers for Disease Control and Prevention (CDC) estimates that, on average, approximately 36,000 people die in the United States each year from influenza. Most at risk are the very young, the elderly and people with underlying health conditions. The New York State Nurses Association (NYSNA) supports the CDC’s recommendation that everyone over the age of six months be immunized against seasonal influenza. NYSNA also supports recommendations that nurses and other healthcare providers should be immunized for seasonal influenza to both protect themselves and vulnerable community members. However, NYSNA does not support mandatory immunization as a condition of employment.

Position

• NYSNA strongly encourages all healthcare facilities to implement comprehensive influenza prevention programs free of charge;
• Influenza vaccination cannot be relied upon as an effective and sole intervention used for the prevention of influenza transmission in healthcare settings;
• Successful vaccination programs should include educational components that address the benefits and common misconceptions about vaccination;
• NYSNA strongly opposes the mandatory immunization of healthcare providers as a condition of employment;
• Patients, visitors and staff should be educated regarding influenza vaccination facts and myths;
• N95 respirators should be made readily available when workers come into contact with patients with influenza-like illness;
• Visitors with influenza-like symptoms should have restricted access;
• Employers should have engineering controls to limit exposure to airborne infectious disease, including adequate ventilation and AIIR (negative pressure) rooms;
• Employees who have influenza should be encouraged to take paid sick time with no repercussions by the employer.

Background

As of 2014, the New York State Department of Health requires that all persons employed or affiliated with a healthcare or residential facility or agency in the state who could potentially expose patients or residents to influenza, either receive seasonal influenza vaccinations or wear a surgical mask during the period when the NYS Commissioner of Health determines influenza is prevalent in New York State, Although the law requires masking for non-vaccinated personnel only in areas where they come into close contact with patients, some facilities have gone beyond those legal requirements by requiring vaccination or masking anywhere on site, even if no patients enter the site.

Face masks are not respirators. Although masks can limit droplet exposure, they do not prevent the spread of lighter, smaller airborne particulates. And, although an important tool in limiting influenza infection and severity, seasonal influenza vaccines vary significantly in efficacy from year to year. Because of these factors, NYSNA believes that in order to prevent the spread of influenza in healthcare facilities, healthcare employers should implement comprehensive infection control plans. These plans should include: 

• Annual influenza vaccinations available to healthcare personnel, patients and visitors, free of charge at a time and place convenient to recipients;
• Strict implementation of standard, droplet and airborne precautions for infected individuals;
• Readily available personal protective equipment for healthcare workers, including N95 respirators, when workers may come into contact with patients with influenza-like illness;
• Active surveillance and influenza testing for patients, staff and visitors with influenza-like illness;
• Access restrictions for visitors with influenza-like illness;
• Paid sick leave for healthcare workers who are experiencing influenza-like illness without repercussions for using leave time;
• Rapid administration of influenza antiviral medications for treatment and, when clinically appropriate, for prevention of disease during influenza outbreaks;
• Education of patients, visitors and staff regarding hand hygiene and respiratory hygiene/cough etiquette;
• Education of patients, visitors and staff regarding influenza vaccination facts and myths;
• Reduction in patient counts in areas where large groups of people gather such as emergency department waiting areas;
• Engineering controls to limit exposure to airborne infectious disease including adequate ventilation and AIIR (negative pressure) rooms. 

NYSNA believes that vaccination plays a significant role both nationally and worldwide in protecting against the spread of infectious diseases. Some diseases, such as polio, have been completely eradicated in the United States due to effective vaccination campaigns. The New York State Code of Rules and Regulations currently requires that healthcare workers demonstrate immunity, or be vaccinated against measles, rubella, and diseases that can be effectively controlled by one or two doses of a highly efficacious vaccine (New York State Title 10, Part 405.3). Influenza, however, is a constantly mutating virus; therefore, a new flu vaccine must be developed and administered annually with varying rates of effectiveness depending on the success of a good match. Influenza vaccination cannot be relied upon as an effective and sole intervention used for the prevention of influenza transmission in healthcare settings until improved technology becomes available, resulting in a more effective “universal” vaccine that does not require the annual updating of antigens. 

Summary and Recommendations

• NYSNA strongly encourages all healthcare facilities to implement comprehensive influenza prevention programs that include voluntary immunization of nurses and other healthcare providers.
• NYSNA believes that successful vaccination programs should include: educational components that address the benefits and common misconceptions of vaccination, availability of the vaccine at no cost at a time and place convenient for workers, and other effective measures as part of a comprehensive infection control plan. In 2009, the Joint Commission issued a monograph with examples of 28 healthcare organizations that have improved their immunization rates by implementing comprehensive infection control strategies. A 2011 article in the Joint Commission’s journal, The Source, provides additional information on improving influenza vaccination rates.
• NYSNA asserts that, through the cooperation of healthcare facilities, healthcare workers and policymakers, we can improve voluntary influenza vaccination rates, establish effective influenza prevention and control efforts, and safeguard the public’s health without the need for mandatory immunization of healthcare workers.

Approved by the NYSNA Board of Directors. Reviewed and revised: March 6, 2018.

References

• Centers for Disease Control and Prevention. (2012). Respiratory hygiene/cough etiquette in healthcare settings. Retrieved from https://www.cdc.gov/oralhealth/infectioncontrol/faqs/respiratory-hygiene.html 
• Centers for Disease Control and Prevention. (2017). Key Facts About Seasonal Flu Vaccine. Retrieved from https://www.cdc.gov/flu/prevent/keyfacts.htm
• State of New York Official Compilation of Codes, Rules and Regulations Title 10 Section 2.59.
• Prevention of Influenza Transmission by Healthcare and Residential Facility and Agency Personnel. Retrieved from https://regs.health.ny.gov/sites/default/files/pdf/recently_adopted_regulations/2014-11-19_prevention_of_influenza_transmission.pdf
• The Joint Commission. (2009). Providing a Safer Environment for Health Care Personnel and Patients through Influenza Vaccination: Strategies from Research and Practice. Retrieved from https://www.jointcommission.org/assets/1/18/Flu_Monograph.pdf