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Exemption, Reasonable Accommodation, and Interactive Process for Mandatory Employee COVID-19 Vaccination

 

Overview

Nova Southeastern University’s Mandatory Covid-19 Vaccination Policy for Employees allows employees to request exemption from the mandatory COVID-19 vaccination requirements based upon qualifying and documented medical or religious reasons.

 

Exemption and Reasonable Accommodation

Employees in need of an exemption from receiving the COVID-19 vaccine based upon the existence of either: (1) an underlying medical condition or disability that contraindicates administration of the vaccine or (2) pregnancy or pregnancy-related medical condition or (3) a sincerely held religious belief, practice, or observance must submit a completed Request for Exemption from Mandatory COVID-19 Vaccination & Reasonable Accommodation Form to the Office of Human Resources (OHR) to begin the interactive accommodation process as soon as possible before the vaccination deadline.

 The initial deadline for an employee’s receipt of the Covid-19 vaccine is September 20, 2021.  Employees who submit their request with supporting documentation by September 1, 2021 should receive a determination from OHR before the September 20, 2021 deadline. Employees are encouraged to submit their requests as soon as possible. Individuals receiving offers of employment are required to timely comply with the mandatory vaccination policy (by providing either proof of vaccination or receipt of OHR vaccine exemption approval) prior to the commencement of employment. Individuals receiving offers of employment from NSU who do not timely comply with this policy will have their offer of employment rescinded.

Accommodations will be granted where they do not create an undue hardship for NSU and/or do not pose a direct threat to the health or safety of others in the workplace and/or to the employee.

 

Procedure

An employee requesting an exemption from the COVID-19 vaccination and who may need a reasonable accommodation must submit a completed Request for Exemption from Mandatory COVID-19 Vaccination & Reasonable Accommodation Form with any required supporting documentation to ohr-ada@nova.edu.

 

Interactive Process

After receipt of an employee’s request for exemption and if approved, OHR will review the documentation submitted and engage in the interactive process with the employee to clarify the nature of the request, determine exemption eligibility, and identify potential reasonable accommodations (with assistance from the supervisor, and/or college/unit administration where necessary). Accommodations will be granted where they do not create an undue hardship for NSU and/or do not pose a direct threat to the health or safety of others in the workplace and/or to the employee.

 

Granting an Exemption/Reasonable Accommodation

OHR will complete the approval section of the Request for Exemption from Mandatory COVID-19 Vaccination & Reasonable Accommodation Form when an exemption is granted noting the duration of the exemption and any required resubmission by the employee and recertification by OHR.  If an accommodation is granted, OHR will describe the nature and scope of the accommodation including any required protective equipment and/or modifications to the employee’s workplace or work life.

 

Denying an Exemption/Reasonable Accommodation

OHR will complete the denial section of the Request for Exemption from Mandatory COVID-19 Vaccination & Reasonable Accommodation Form when an exemption and/or accommodation is denied with a notation of the reason for the denial. Denial of an exemption and/or reasonable accommodation request may be reviewed through NSU’s appeal process.

 

Exemption Appeal Process

An employee who is denied an exemption by OHR may appeal the decision by submission of a completed Appeal for Denial of a Requested Exemption from the COVID-19 Mandatory Vaccination Policy to OHR within five (5) calendar days (Monday – Friday) of receipt of the decision denying exemption. Filing of appeal does not extend the deadline for an employee to comply with the Mandatory Covid-19 Vaccination Policy for Employees. Submit the completed appeal form to ohr-ada@nova.edu.

The panel reviewing the employee’s appeal shall consist of Executive Vice President and Chief Operating Officer Dr. Harry Moon, Vice President of Human Resources Robert Pietrykowski, Dean of the Dr. Kiran C. Patel College of Allopathic Medicine Dr. Johannes Vieweg, and Dean of the Dr. Kiran C. Patel College of Osteopathic Medicine Dr. Elaine Wallace. The appeal panel may request additional information from the employee and/or OHR, and additional medical documentation from the employee. The appeal panel may decide to affirm OHR’s denial or overturn OHR’s denial and grant the employee’s request in whole or in part.

Please direct any questions regarding this policy to Director of Benefits Arlene Walsh at awalsh@nova.edu.

 

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