April 26, 2021

COVID-19 Vaccination Program

1. Policy

Issued: 3/5/2021
Edited: 4/26/2021

2. Policy Purpose

The purpose of the COVID-19 Vaccination Program is to protect and support the health and safety of the USC Community including the University’s faculty, staff, students, and patients.

3. Policy Statement

All University faculty, staff, and students who are on-campus are required to receive the SARS-CoV-2 vaccine (“COVID-19 vaccine”) by June 1, 2021. For so long as the COVID-19 vaccines are authorized for emergency use only and are not yet approved by the U.S. Food & Drug Administration (FDA), faculty, staff, and students may comply with this policy by affirmatively opting-out of COVID-19 vaccination by submitting a Personal Declination Form.

[DRAFT] Policy – FDA-issued Approval: If/when the FDA issues approval of at least one of the COVID-19 vaccines, all faculty, staff, and students eligible to receive an FDA-approved vaccine will be required to receive such vaccine in order to access University campuses and premises or participate in any in-person University programs or activities and any previously submitted Personal Declination Forms will no longer be valid. Any faculty, staff, or student who is unable to receive an FDA approved COVID-19 vaccine due to a disability or sincerely-held religious practice, belief, or observance, may request an exception to this policy once enacted. Updated participation requirement details will be announced following FDA approval. A person who is granted an exception may be required to use additional personal protective equipment or take other actions such as participation in ongoing testing as directed by the University for the health and safety of the University community.

The vaccine will be available, per state guidelines and pending availability, at no charge, to all University faculty, staff, and students who are on-campus.

4. Scope and Application

This policy applies to faculty, staff, and students who work or study on-campus at the University.

5. Definitions

Defines terms specific to this policy.

Term	Definition
COVID-19 Vaccination Program	Vaccination Program that requires one of the following: COVID-19 vaccination; submission of a Personal Declination Form (during the Emergency Use Authorization Period); or submission of a Disability Exemption Form or Religious Exemption Form (following FDA Approval of the COVID-19 vaccines) or for USC’s faculty, staff, and students who are on-campus.
Emergency Use Authorization Period	The period during which the COVID-19 vaccines are authorized for emergency use by the FDA, but prior to approval by the FDA.
On-Campus	For purposes of this policy, a location is considered on-campus if it takes place within USC’s Clery geography, as defined in the Annual Security & Fire Safety Report issued by the USC Department of Public Safety. This includes, but is not limited to, UPC, HSC, USC Village, USC Housing, and the Coliseum.

6. Policy Details

Employees who work at Keck Medicine of USC or at one of USC’s Ambulatory Clinics should refer to Keck Medicine of USC-specific policies related to COVID-19. To be clear, this policy excludes employees who work at Keck Medicine of USC, including but not limited to those who work at Keck Hospital of USC, USC Norris Cancer Hospital, USC Ambulatory Clinics, and USC Verdugo Hills Hospital.

Participation Requirement during Emergency Use Authorization Period: For so long as the COVID-19 vaccines are authorized for emergency use and not approved by the FDA, faculty, staff, and students will be required to comply with the COVID-19 Vaccination Program by completing one the following steps by June 1, 2021:

Receive vaccination on-site when eligible.
Provide written documentation of vaccination from an external healthcare facility or clinic (e.g., at a private health care provider’s office or during a vaccine fair).
Personal Declination: Formally decline the vaccine by submitting a Personal Declination Form in MySHR. Individuals submitting a Personal Declination Form may opt to receive the vaccine in the future.

[DRAFT] Policy – Policy Participation Requirement Following FDA Approval: Upon FDA approval of any one of the COVID-19 vaccines, USC will review this policy, and all Personal Declination Forms previously submitted will no longer be sufficient to comply with this policy. Following FDA approval, the University will announce details for completing the to-be-determined Participation Requirement along with appropriate Disability and Religious Exception Forms.

Program Enforcement: Any faculty, staff, or student who fails to comply with this policy (whether through vaccination or by submitting a Personal Declination Form, Disability Exemption Form, or Religious Exemption Form, as applicable) by the established deadline will be unable to be on-site in any capacity. Non-compliance will also be referred to the faculty and staff or student COVID-19 compliance review teams. To the extent permitted under federal, state, and local law, any unvaccinated person may be required to use additional personal protective equipment or take other actions such as participation in ongoing testing as directed by the University to mitigate risk to faculty, staff, students, and patients whenever they are on-site at a USC location.

Registry and Program Evaluation: Appropriate information about all vaccinations shall be submitted to the California Immunization Registry or such other registries as may be required by applicable public health agencies or University policy.

7. Procedures

Method of submission:

During the Emergency Use Authorization Period, faculty, staff, and students must comply with this policy by completing one of the following:

Faculty, staff, and students upload COVID-19 vaccination administration documentation through the Electronic Health Record (EHR) portal, MySHR.
Faculty, staff, and students who receive vaccination at any USC Pharmacy or healthcare facility or clinic will automatically satisfy the requirement.
Personal Declination Form (sample enclosed and click here for fillable PDF): must be completed by the faculty member, staff, or student (or parent/guardian if employee or student is less than 18 years of age).

Following FDA Approval of any vaccine, participation requirement details will be announced.

8. Forms

Personal Declination Form for Required COVID-19 Vaccination.

All medical information submitted in course of the COVID-19 Vaccination Program will be kept in a separate confidential file in MySHR.

9. Responsibilities

POSITION or OFFICE	RESPONSIBILITIES
USC Student Health	Maintaining and implementing this policy.
SVP of Administration	Authorized to issue official university policy.
All faculty, staff, students	Expected to comply with university policy.
Departments with contractors or visitors	Departments with contractors or visitors should follow any established procedures for contractors or visitors.

10. Related Information

References:

Cal. Health & Safety Code Division 2, Chapter 2, Article 3.5

CDC COVID Vaccination Program Planning Guidance

CDC Vaccine Recommendation Process

USC Notice of Non-Discrimination

11. Contacts

Please direct any questions regarding this policy to:

OFFICE	PHONE	EMAIL
COVID-19 Hotline	213-740-6291	Covid19@usc.edu

12. Effective Date

This is a revised policy effective April 26, 2021.

13. Policy URL:

The policy will be listed at policy.usc.edu. This link may be shared in community messages and on the We are SC website.