[MCOH-EH] [External] immunizations/ TB testing who pays?

[Mazo, James]

Phil,

Great question for the health center employee health services group.   These are indeed trying financial times in medicine and I to find administration at most hospitals trying to cut cost by whatever means possible.  We require multiple vaccinations and titers for our pre-employment hires, cost of which is incurred by the institution in the current state.  The only regulation that I can find is the hepatitis B vaccination and titers, and blood-borne pathogen testing as you stated.  OSHA is silent on the topic of pre-employment testing remuneration, but if it is a mandate for employment, I think the legal system would enjoy the opportunity to litigate the pushing of such mandated testing and vaccination costs onto the pre-hire at their expense.  If it is a condition of employment, the employer is to incur the costs.  As to "farming out" pre-employment exams and testing, I would welcome them to perform a cost analysis of your services, and I am sure that in-house exams are a great cost savings compared to a third party urgent care center.

My opinion only,

JEM

James E. Mazo, MD, FACOEM
Medical Director and Section Chief Occupational Medicine
Saint Francis Hospital and Medical Center
A Member of Trinity Health Of New England
jmazo at stfranciscare.org
W  860-714-5339
F  860-714-8068
114 Woodland Street
Gengras 4320
Hartford, CT 06105


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-----Original Message-----
From: MCOH-EH [mailto:mcoh-eh-bounces at mylist.net] On Behalf Of Philip Adamo
Sent: Wednesday, November 07, 2018 11:12 AM
To: MCOH/EH
Subject: [External] [MCOH-EH] immunizations/ TB testing who pays?

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Hello colleagues,
I have been in EHS for various hospital for over 20 years. The hospitals/medical centers have always provided the required immunizations and TB testing and assume the costs of delivering this service.

I have been approached by one of our leaders that the hospital should only consider employing someone if they meet our immunization requirements and that they pay to go to their PCP for immunizations and TB testing. I know OSHA specifically addresses that the Hospital pays for the Hep B vaccination and titters in the BBP regulation. I cannot find other documents to supporting that hospitals are not responsible fro MMR V and Tdap as well as TB testing.

There was also a suggestion that we contract out the pre-placement to an urgent care center. The candidate would then come to EHS for the mask fit, and clearance.

I am currently at a large academic medical center. My opinion is that there is so much wrong on many levels with tis approach. I would like to get opinions from many of you especially of this process works.

Best regards,

Philip Adamo, M.D., MPH, CPE
Baystate Health
Springfield, MA
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