American College Health Association Recommends COVID-19 Vaccination Requirements for All On-Campus College Students in Fall 2021
April 29, 2021
The in-person and residential college experience on campuses throughout the United States has been profoundly curtailed by the COVID-19 pandemic in 2020-21. There have been enormous impacts on our college communities, including economic, academic, social, physical, and mental health consequences for students, faculty, and staff. The American College Health Association (ACHA) recognizes that comprehensive COVID-19 vaccination is the most effective way for institutions of higher education (IHEs) to return to a safe, robust on-campus experience for students in fall semester 2021. Therefore, where state law and available resources allow, ACHA recommends COVID-19 vaccination requirements for all on-campus college and university students for fall semester 2021, in accordance with the IHE's normal exemption practices, including exemptions for medical contraindications. This recommendation applies to all students who live on campus and/or participate in on-campus classes, studies, research, or activities.
Pre-matriculation vaccination requirements for students attending IHEs in the United States are not new and are time-tested. Most U.S. campuses have had vaccination requirements for decades, recognizing that vaccination is a primary strategy for advancing campus health by preventing outbreaks of vaccine-preventable diseases. A 2018-2019 ACHA Institutional Profile Survey showed that 68% (138/203) of respondent IHEs required measles vaccination for all students, and another 19.7% (40/203) required measles vaccination for some students (e.g., on-campus/face-to-face students, health science students). Many campuses also require vaccinations against mumps, rubella, varicella, and other vaccine-preventable diseases. Both Centers for Disease Control and Prevention (CDC) and ACHA have detailed recommendations for pre-matriculation vaccination of college students. COVID-19 is a vaccine-preventable illness not unlike those for which vaccines have been required in the past.
Although it is common for the public to view U.S. colleges and universities as a population of healthy 18–23-year-old students, many students, faculty, and staff are in older age groups and/or at high risk for severe COVID-19 illness and complications. In addition, long-standing health inequities in our nation have placed many of our college community members of color at a higher risk of COVID-related morbidity and mortality. During the fall of 2020, re-opening of IHEs was associated with an increase in surrounding community COVID-19 incidence. A COVID-19 vaccination requirement helps to protect the campus via community (herd) immunity. Importantly, protection is also provided to the community around the campus; high-risk individuals at the IHE; and those students, faculty, and staff who have IHE-approved exemptions that preclude COVID-19 vaccination.
In addition to the obvious physical and mental health advantages offered by a highly vaccinated campus population, there are economic, academic, and social advantages. The resumption of continuity in the academic, extracurricular, and residential experience will, once again, enhance students’ personal, professional, and academic growth. IHEs would benefit by referring students, faculty, staff, and parents to CDC’s recent Interim Public Health Recommendations for Fully Vaccinated People.
In order to successfully and appropriately implement a COVID-19 vaccination requirement for students, a number of issues should be carefully considered and addressed:
- At this time, the three COVID-19 vaccines available in the United States are under an FDA Emergency Use Authorization (EUA). There are indications that the EUA designation may convert to full FDA approval soon. Although opinions differ, many legal experts have stated that EUA status does not preclude an institutional vaccination requirement. IHE leadership should have in-depth discussions with legal counsel when deciding on a course of action in the event of ongoing EUA status of one or more of the vaccines.
- IHEs should continue with concerted efforts to vaccinate as many students, faculty, and staff as possible prior to the end of spring 2021 semester. For students, this will help simplify compliance with a fall COVID-19 vaccine requirement. In addition, it will positively impact the public health risk of the end-of-semester “mass migration” of students to other cities, states, and countries, leading to potential transmission of the virus from students who may be infected but pre-symptomatic or asymptomatic. Taking steps to vaccinate students now will contribute to the national effort to bring a close to the pandemic.
- IHEs should encourage students to get vaccinated at the earliest opportunity to do so. If the initial dose of a two-dose vaccine is received on campus, the IHE should share strategies with students for getting the second dose by the same manufacturer in a location other than the campus community.
- IHEs should identify campus populations with low vaccine confidence and support culturally appropriate education and outreach to increase vaccine uptake.
- Many students will be coming back to campus from areas of the country and the world where substantial health inequities exist and vaccine availability is limited (or U.S.-approved/EUA vaccines are not available). To reduce incidence of disease importation to campus, these students will need both COVID-19 testing and immediate access to vaccination upon arrival on campus. IHEs should refer to local, state, territorial, tribal, and federal guidelines to evaluate the efficacy of vaccines that are not approved in the U.S. When appropriate, these students should be offered access to revaccination.
- Colleges and universities should support students with IHE-approved exemptions, including appropriate access to on-campus activities that meet CDC mitigation recommendations and a well-designed testing protocol. IHE leadership should determine ways to protect the rights, dignity, and privacy of these students while limiting the risk presented by an unvaccinated cohort of students at the beginning of the semester and throughout the academic year.
- IHEs will need to develop an approach to COVID-19 vaccination documentation that allows for appropriate and protected storage of vaccination details. Most campuses already have a procedure in place for other required pre-matriculation vaccinations, and a similar process can be utilized.
- Leadership should examine the impact of the co-mingling of vaccinated and unvaccinated visitors to the campus, including those attending intercollegiate athletic events, arts and cultural events, commencement, and other large congregate gatherings.
- IHEs should examine the additional positive impact of a COVID-19 vaccine requirement for faculty, staff, and contractors on campus. At the very least, a vaccination requirement for all frontline student health staff is recommended, and faculty and non-health service staff should be strongly encouraged to get vaccinated. Every unvaccinated individual on the campus presents a risk to themselves and to the campus community.
ACHA supports policies and approaches at IHEs that will maximize COVID-19 vaccination on our campuses. However, ACHA recognizes that each IHE will need to make its own individual decision about a vaccination requirement based upon its unique circumstances, including state restrictions, make-up of the campus population, vaccine availability, and staffing and other available resources. At colleges and universities where a COVID-19 vaccination requirement for fall 2021 is either not possible or is deemed by IHE leadership to be not in the best interest of the campus community, it will be vitally important for leadership to strongly encourage vaccination of all students, faculty, and staff. Updated CDC- and ACHA-recommended COVID-19 testing and mitigation strategies should continue to be in place in fall 2021 and beyond.