The Ministry of Health and Family Welfare (“MOHFW”) on April 07, 2021 has issued a guidance note concerning COVID-19 Vaccination at workplaces of Government and Private with effect from April 11, 2021. Some of the relevant aspects provided in the guidance note, as applicable to a private sector, are provided as below:
What is the object for COVID-19 vaccination at workplace?
As per MoHFW, a substantial proportion of population aged between 45-59 years (in some cases up to 65 years) are in the organized sector of the economy wherein they are involved in formal occupation in offices (government and private), in manufacturing and services etc.
Therefore, COVID-19 vaccination sessions may be organized at workplaces that have 100 ‘eligible’ and ‘willing’ ‘employees’ (to facilitate optimal utilization of vaccine dosage and reduce wastage) for COVID-19 vaccination.
The purpose is not only to extend convenience to eligible employees but also help them avoid travel to vaccination centers, thereby, reducing the risk of exposure to COVID-19 virus.
Which workplace shall be covered for COVID-19 vaccination?
Only such workplaces which have 100 and more ‘eligible’ and ‘willing’ employees shall be eligible to extend vaccination at workplace.
Who shall identify the workplace for COVID-19 vaccination?
District Task Force (DTF) chaired by District Magistrate and Urban Task Force (UTF) chaired by Municipal Commissioner have been assigned the task to identify private workplaces after due deliberations with relevant employers and / or head of offices.
The management of a workplace has been assigned the duty to designate one of their senior staff to work as “Nodal Officer” to coordinate with district health authorities/ private COVID Vaccination Centres (CVCs) and support vaccination activities. The Nodal Officer is expected to oversee and facilitate all aspects of vaccination at workplace CVC including registration of beneficiaries, availability of physical and IT infrastructure and vaccination, etc.
Who is eligible?
Only employees at workplace aged 45 years or more will be eligible (beneficiaries) for vaccination. No outsiders including eligible family members are allowed to avail this facility. Beneficiaries must be registered in Co-WIN portal prior to vaccination.
Nodal Officer will ensure registration of all targeted beneficiaries and facility of on-the spot registration will also be available but only to employees of a workplace.
Who shall vaccinate?
One fully trained vaccination team is expected to be assigned to vaccinate 100 eligible employees at workplace CVC. Additional teams are expected to be deployed in case work load is more than 100 beneficiaries and if sufficient space for vaccination is available. The management of a workplace is responsible for arranging adequate rooms / space for COVID-19 inoculation, etc.
Which vaccines will be administered?
Only one type of vaccine, from the one available in India, are to be provided for inoculation sessions at workplaces to avoid mixing vaccine types in the first and second dose of a beneficiary.
Beneficiaries at workplaces, who have already received one dose of a vaccine different from the one being administered at a workplace CVC are not to be vaccinated at the workplace facility. However, those who have received the same vaccine (as first dose), as being provided at workplace CVC, may be provided the second dose at the workplace CVC.
How much will the Covid-19 vaccine cost?
COVID-19 vaccination programme organised at private offices / workplace (CVCs) will be on a payment basis and will be same as that of vaccination at a private health facility i.e. service charge subject to a ceiling of Rs. 100 /- per person per dose and a vaccine cost of Rs. 150/- per person per dose. Therefore, for private workplace, the financial ceiling of the total amount recoverable by private health facility is INR 250/- per person per dose. A private health facility that will be organizing vaccination at the private sector’s workplace will deposit cost of vaccines upfront in the government designated bank account.
Guidance note does not provide whether the owner (employer) of a private workplace should incur the cost or the eligible employees will be obligated to pay the same.
Relevant link to the Guidance Note as published by the Ministry of Health and Family welfare is provided hereinbelow for reference purposes and for further details as provided therein:
-Manishi Pathak, Founding Partner & Ranjan Jha, Partner
Disclaimer: The contents of the above publication are based on easier understanding of relevant contents of a government notification/ guidelines/ publication and a reader should refer to such a notification/guidelines/ publication for further or specific details/ information, which will override the contents hereof. These are personal views of authors and do not constitute a legal opinion, analysis or interpretation. This is an initiative to share developments in the world of law or as may be relevant for a reader. No reader should act on the basis of any statement above without seeking professional legal advice.