This Policy sets forth the principles Washington University in St. Louis hereafter referred to as (WashU), will follow to protect patients, students, faculty and staff, whenever possible, from exposure to certain communicable illnesses. In appropriate situations, aspects of this policy will apply university-wide. Clinical guidance relevant to specific communicable illnesses, including active tuberculosis disease, influenza, conjunctivitis, and infection with human immunodeficiency virus (HIV), and Hepatitis B and C, among others, will be developed by medical staff, including the Division Chief of Infectious Diseases and the Director of Occupational Health.
It is the policy of WashU to review, evaluate, and respond on an individual case-by-case basis, when possible, to any known suspected or confirmed instances of certain communicable illnesses among members of the WashU community which may be transmitted in a normal business, academic or patient care setting. Such individual review, evaluation, and response should take into consideration applicable federal and state laws; the recommendations of the U.S. Public Health Service, the Centers for Disease Control, the Association of American Medical Colleges, the American College Health Association, and various professional associations; other relevant medical, scientific, and legal literature; the expressed desires and opinions of the individual with such illness and the individual’s personal physician; and the university’s commitment to the protection, to the extent possible, of both public health and individual rights.
WashU recognizes that employees with any suspected or confirmed communicable illness may wish to continue their employment. As long as they are able to meet acceptable performance standards, comply otherwise with all other required Occupational Health policies which describe mandatory screenings and vaccinations, and the medical evidence indicates that their conditions are not a threat to themselves or others, it is the policy of WashU that these employees be treated consistently with other employees in matters of employment. All members of the WashU community will be evaluated on a case-by-case basis, when possible, to determine what if any restrictions apply, given the type of illness, the individual’s health status, and the nature of work or work setting, among other relevant factors. In the setting of a large epidemic or pandemic, case-by-case evaluation may not be possible and broad restrictions may be implemented.
WashU’s Responsibilities to Patients, Faculty, Staff and Students
WashU will address issues involving communicable illnesses in a sensitive and responsible manner, with concern for the rights and welfare of patients, faculty, staff and students.
- Obligation to Treat Patients. Clinical services of WashU rest in the hands of the patient care providers who are expected to be at work when scheduled to ensure we provide the best possible care to our patients. WashU faculty and staff with patient care responsibilities may not refuse to treat a patient whose condition is within their realm of competence solely because the patient has a suspected or confirmed communicable illness. Faculty and staff with certain conditions placing them at higher risk of infection and/or complications, including but not limited to compromised immune system and pregnancy, may be reassigned to duties with lower risk of exposure to the communicable illness.
- Medical Records. If a patient has a suspected or confirmed communicable illness, this information should be included in the patient’s medical record. Medical record results should contain only objective information that is relevant to the patient’s care and treatment. The patient’s medical record must be afforded the same confidentiality protections that WU affords other medical records. Care should be taken to ensure that the patient’s medical record is not disclosed to others except as required or permitted by law or as authorized in writing by the patient. All medical records and the patient information therein must be handled in accordance with the Health Insurance Portability and Accountability Act (HIPAA).
- Communicable Illness Screenings. Any member of the WashU community who believes he or she has contracted a communicable illness that may be transmitted in a business, academic or patient care setting must contact Occupational Health to report the symptoms or illness. During certain communicable disease outbreaks such as a large epidemic or pandemic, all members of the WU community may be required to undergo mandatory health screening and/or health status reporting on a regular basis. Such provisions will be activated upon emergency order from the Dean or the Dean’s designee and will be implemented by Occupational Health and the Infectious Diseases Division, based on available federal recommendations. Under such emergency provisions, WU may require individuals who travel to and from countries with active communicable illness outbreaks to report all such travel to Occupational Health and to undergo testing and screenings considered medically appropriate prior to returning to work. This also applies to new members of the WashU community coming from such countries who must be screened prior to beginning their WU appointment. WU business travel may be suspended and position appointments delayed under such provisions.
- Medical Care. Individuals with suspected or confirmed communicable illnesses are encouraged to seek proper medical care, counseling, and education. Faculty, staff and students should look primarily to their personal physician for appropriate medical care and counseling. Any WashU employee or student with a suspected or confirmed communicable illness who is experiencing difficulty in obtaining expert medical care and counseling is encouraged to seek assistance from Occupational Health and the Infectious Diseases Division. At any time, WU may require an individual to be assessed by a WU-appointed physician to determine fitness for duty.
- Confidentiality. WashU recognizes the importance of protecting, to the greatest extent possible, the confidentiality and privacy interests of all employees and students suspected of having or who have a communicable illness. Accordingly, such information should be handled with the same degree of care and sensitivity as is accorded to other types of highly confidential medical information and, if applicable, in compliance with HIPAA. WU will disclose sensitive medical information of employees and students no further than is necessary to ensure the health and safety of WU employees, students and patients and in a manner consistent with applicable law. Appropriate licensed medical staff (to include a WU-appointed physician or the employee’s physician) will be solely responsible for assessing an employee’s relevant clinical information to determine fitness for duty or identify relevant work restrictions. Only the results of this assessment of fitness for duty will be shared confidentially with Human Resources when needed to manage employment and work related issues.
- Reporting and Review Requirements for Certain Communicable Illnesses. Faculty or staff members who know they have a communicable illness or who have a reasonable basis for believing that they have a communicable illness have an obligation to conduct themselves responsibly for their own protection and the protection of patients and other members of the university community. Faculty or staff members with communicable illnesses must not knowingly engage in any activity that creates a material risk of transmission to others.Decisions regarding restrictions on or modifications of employment and academic duties/activities and access to facilities or programs as a result of a communicable illness will be made on a case-by-case basis, when possible, depending on the type and nature of the communicable illness, the nature of work or work setting, and the risk to the health of the individual or others. Such restrictions or modifications may include, among other things, changes in job functions, location, or work schedule, and/or removing the individual from the work setting. WU shall make efforts to implement such decisions as discreetly and confidentially as possible, with as little harm as possible to the person, his/her career, and his/her standing in the community.Occupational Health, in conjunction with the Division of Infectious Diseases, will establish clinical guidelines which govern reporting, screening, treatment and safety protocols and return-to-work standards for specific communicable illnesses. This policy will be administered in conjunction with these policies. All members of the WU community must comply with these provisions.
- Pay During Periods of Illness or Quarantine.Certain communicable illnesses may require a period of time away from the workplace in order to protect the health of others. In order to encourage those with symptoms to stay home to care for themselves or for family members who are ill, employees will not be penalized for requesting time away.
Quarantine or other required period of absence from work. Where medically required, and/or recommended by the CDC, employees will be expected to comply with quarantine or other such restrictions as prescribed by the school or by a public health official. Where quarantine is imposed due to an employee’s exposure while performing work directed by the school, the employee will be paid regular pay and will not have sick or vacation balances reduced during the period of quarantine. Such period will last until the specified period of time ends or the employee becomes actively ill with the communicable disease, whichever comes first.
Non-work related exposure result in quarantine/absence will be paid based on the availability of the employee’s sick or vacation time.
FMLA and /or Worker’s compensation may apply during the period of quarantine.
Periods of communicable lllness. Pay for periods of personal illness will normally be provided through the use of available sick or vacation time. In cases where employees are serving an orientation period and do not have available sick or vacation time, such time may be advanced upon approval of the Department.
Under certain conditions affecting the entire WU community such as a large epidemic or pandemic, the Dean may enact emergency time off provisions to cover periods of personal illness. Where such illness may be determined to have been contracted due to the performance of work at the employer’s direction, employees may be granted up to five (5) paid days away from the office due to illness without impacting sick or vacation balances. Once exhausted, standard time off and leave policies apply.
In the case of a vaccine-preventable communicable disease outbreak, employees who are not vaccinated and who risk possible exposure to the vaccine-preventable communicable disease in the course of their duties in the workplace will be sent home until the risk of possible workplace exposure is mitigated. In these cases, the employee will be required to use their vacation time. If the employee becomes ill with the vaccine-preventable communicable disease, the applicable provisions above will apply.
Absences due to personal illness may qualify as FMLA and may be subject to workers’ compensation.
- Support Services.WashU will build on the programs of Occupational Health so that all members of WashU will have available and accessible to them services through which they can obtain information, expert counseling, expert medical care, assistance in locating and using community resources, and, as appropriate, referrals to such resources. Information about this policy will be covered in available management forums to include New Employee and New Faculty Orientation.
- Additional Resources.The following university offices and federal agencies are available to provide information and respond to questions about communicable illnesses.
- Occupational Health, Campus Box 8030 (314-362-3523)
- The Environmental Health and Safety Office, Campus Box 8229 (314-362-6816)
- WU Student Health, Campus Box 1069 (314-935-5547)
- Division of Infectious Diseases, Campus Box 8051, (314-454-8354)
- Habif Health and Wellness Center, Campus Box 1201 (314-935-6666)
- Centers for Disease Control and Prevention
Employees who work extended hours or other than day shifts should report symptoms to their supervisor and may be directed to the Emergency Room at Barnes-Jewish Hospital or to their private physician.