In the March 16 edition of the Wisconsin Banker Daily, WBA shared information about on-site vaccine clinic requests. Wisconsin’s vaccine distribution is rapidly evolving, and Governor Tony Evers announced yesterday that people with certain medical conditions will be eligible for the COVID-19 vaccine on March 22, which is a week earlier than previously expected. In addition, Milwaukee is further expanding vaccine eligibility for all people age 18 and older living in 10 at-risk ZIP codes that rank high on an index of social vulnerability. See more on the ZIP code-based eligibility in Milwaukee. WBA Legal and Communications have worked together with Boardman & Clark to develop the following FAQs for Wisconsin banks. Banks should reach out to legal counsel for specific advice on their individual circumstances when contemplating or establishing an on-site clinic. 

Important Dates:  

  • March 17:  Vaccinators who will administer vaccines at on-site clinics must have their allocation requests into DHS by March 17 to receive doses for the weeks of March 29 and April 5. Contact a local vaccinator today if you wish to host an on-site vaccination clinic in the coming weeks.  WBA understands that it may be difficult to find available vaccinators in the short term due to high demand of their services.  
  • March 17: Milwaukee is expanding vaccine eligibility for all people age 18 and older living in 10 at-risk ZIP codes that rank high on an index of social vulnerability. https://county.milwaukee.gov/EN/COVID-19/COVID-19-Vaccine 
  • March 22:  Vaccine eligibility expands to include individuals age 16 and older with specified medical conditions.  
  • May 1:  DHS plans to open vaccine eligibility to all individuals age 16 and older.  

The COVID-19 vaccination program is rapidly evolving, and the state and federal governments will continue to communicate information as it becomes available. 

Question 1: Who provides and administers the vaccines for an employer-based vaccination clinic? 

Answer: Only state-authorized vaccinators, such as hospitals, doctor’s offices, pharmacies, and public health departments, can obtain and administer vaccinations. An employer must locate and work with an approved vaccinator to start the process of hosting an employer-based vaccination clinic. A list of vaccine providers is available here. Due to the fact that many of these vaccinators may be fully occupied at their regular places of employment, it may be difficult from a practical perspective to find available vaccinators at this early time. Once located, work with the vaccine provider to determine a targeted date, location, and number of vaccines needed for the clinic. Vaccinators who intend to request an allocation of vaccine specifically to support a closed, employer-based clinic can now make a separate request to DHS receive a dedicated allocation as vaccine & supplies are available. Banks may inform their employees that they must give notice if the employee intends to get vaccinated at the on-site clinic. The vaccine provider will submit a request to DHS for the vaccine. Requests will be accepted through the current bi-weekly allocation survey every other Wednesday, beginning on March 17. The vaccine provider will be notified by DHS if the request is approved. Please keep in mind that requests for vaccine exceed the current supply and DHS will not be able to fulfill all requests.  

DHS has issued the following documents for employers who would like to host a clinic in their workplace:  

DHS Guidelines: Wisconsin Employer-Based COVID-19 Vaccination Clinics  

DHS COVID-19 Vaccination Program: Planning a Vaccination Clinic Checklist  

Additional information is available from the CDC:

CDC Recommendations: Workplace Vaccination Program  

Question 2: How do I determine whether my bank needs an on-site vaccine clinic?  

Answer: Whether a bank should offer a “closed clinic” to those employees currently eligible for vaccination is a business decision to be made by the bank. Some institutions have a significant number of employees who are eligible, other institutions do not. In order to determine if there is sufficient employee interest to warrant an on-site vaccine clinic (and so that the vaccinator can order sufficient supply of the vaccine), banks can ask employees if they have received the vaccine already or if they wish to receive the vaccine through a potential on-site clinic. Such information must be retained confidentially. Due to anti-discrimination laws, banks should not ask follow-up questions such as why an individual might or might not wish to receive the vaccine. Additionally, banks may be asked by vaccinators to prioritize employees in case they do not receive the full requested number of vaccines. Employers must be careful to comply with applicable anti-discrimination laws when prioritizing employees. To that end, creating the prioritization list based on employee job duties is advisable. 

Question 3: Where are bank employees prioritized in the COVID-19 distribution by the state?   

Answer: Despite efforts by our financial services coalition, bank employees — public-facing or otherwise — have not been designated as eligible as a group for the vaccine at this time by the Department of Health Services (DHS) or the Governor’s administration. However, bank personnel may be eligible to receive the vaccine using criteria that isn’t specific to their occupation, such as being 65 or older. Beginning March 22, overall vaccine eligibility will be significantly expanded to include individuals ages 16 and over who have certain health or medical conditions. For a list of individuals currently eligible, and those who gain health-related eligibility on March 22, please refer to this release from Gov. Evers.  

Question 4: What timeline do employers need to keep in mind?  

Answer: If an employer would like to host a clinic the week of March 29 or April 5, they must reach out to a vaccinator as soon as possible as vaccinators must submit their requests to DHS today (March 17). Those who miss the March 17 deadline must wait until March 31 to be approved. Also, keep in mind that eligibility for vaccines will be greatly expanded on March 22 when individuals age 16 and older with specified medical conditions will become eligible for vaccination. Therefore, an on-site clinic offered after March 22 may reach a greater percentage of your workforce. 

Question 5: What information can bankers provide to employees seeking vaccines?  

Answer: Employees may be directed to the DHS webpage COVID-19:  Where Can I Get Vaccinated for more information. WBA members are invited to attend the upcoming webinar for more information.

WBA Webinar – Coronavirus Management Series:  Vaccinations & Beyond  

On Thursday, March 25 from Noon - 1:30 p.m., WBA will be hosting Coronavirus Management Series: Vaccinations & Beyond, a free webinar detailing the current status of the COVID-19 pandemic. The webinar will be recorded and available to the membership following the live webinar.