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Vaccine Verification Program

Vaccine Verification Program

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Official Guidance

This website outlines the requirements for an indoor space subject to Boulder County Public Health Order 2021-08 to become an Approved Vaccine Verified Facility or Event. Once approved by Boulder County Public Health, Approved Fully Vaccinated Facilities and Events may allow individuals within the approved indoor public space to remove their masks.

Read more about the universal face covering order.

Vaccine Verified Facility & Event Basic Requirements

There are three basic requirements for the Vaccine Verified Facility program:

  • Must have a written policy requiring proof of vaccination for all individuals entering the indoor space (visitors, guests, employees, staff, etc.)
  • Must have 95% of all individuals vaccinated
  • Other mitigation strategies if needed

Report a Concern about COVID-19

Program Overview

By verifying that 95% of the individuals in their indoor space are fully vaccinated, Approved Vaccine Verified Facilities and Events receive exceptions to Boulder County Public Health’s Indoor Mask Order. Facilities can choose to have certain spaces or times of day designated as Vaccine Verified to meet their individual needs.

Public Health Order 2021-08 requires that all individuals age 2 and older must wear a mask in all indoor public spaces in Boulder County.

Under Boulder County Public Health’s mask exemption program, approved facilities must maintain at least a 95% vaccination rate among staff and patrons at all times. To more accurately reflect program requirements, Public Health has updated the program name from “Fully Vaccinated Facility” to “Vaccine Verified Facility.”

Eligibility & Application

To become and operate as a Vaccine Verified Facility or Event, the owner or operator of the indoor space must do the following:

Submit an Application

  1. BCPH will review the submitted application to make sure the below three requirements are met and follow up with requests for more information, if any.
    • Written Policy: The facility or event must have a written policy and process requiring proof of vaccination for all individuals entering the indoor space.
    • 95% Rule: The policy results in the facility or event verifying that at least 95% of the individuals in its indoor space are fully vaccinated, including employees, staff, guests, members, visitors, children under 12, etc. Small business employers (fewer than 100 employees) who cannot reach the threshold of 95% vaccinated are encouraged to call 970-599-1256.
    • Additional Mitigation Strategies: BCPH will consider whether the facility or event, if necessary, has implemented additional mitigation strategies such as increased ventilation and air circulation, requiring distancing between members of different households, symptom screening, and/or encouraging proper hand hygiene.
  2. BCPH will either approve, approve with conditions, or deny the application.
  3. Upon approval, the facility or event must post approved signs indicating proof of vaccination is required for entry. Once the facility or event implements its policy, it may start permitting individuals within the facility to remove their masks after verification of proof of vaccination for all individuals and pursuant to the approval.

Eligible Businesses, Facilities, & Events

Any business, event, or organization operating in an indoor space may apply to become a Vaccine Verified Facility or Event. A Vaccine Verified Facility or Event may apply to an entire building 24/7, certain times and dates, certain rooms within the facility, or may just be limited to a single event at that facility.

This program is designed to be flexible to meet the needs of our diverse community.

Although there are no requirements for masks outdoors, facilities and events may choose to implement proof of vaccination requirements for outdoor spaces. However, approval from Boulder County Public Health is not necessary for outdoor spaces.

Ineligible Facilities/Businesses/Events

Facilities and events subject to state or federal orders requiring face coverings regardless of vaccination status, including facilities subject to the Colorado Department of Health Public Health Order 20-20 (long term care facilities etc.) and the CDC Transportation Order are not eligible for this program.

Childcare and PK-12 schools subject to Boulder County Public Health Order 2021-07 are not eligible for the vaccine verification program. Youth activities and sports subject to Public Health Order 2021-07 are not eligible for the vaccine verification program.

Examples of Vaccine Verified Facilities & Events

A non-exhaustive list of examples of the flexibility of this program include:

  • A business may become part of the Fully Vaccinated Facilities program by requiring proof of vaccination for all employees and proof of vaccination for everyone entering the building at any time. For example, an art studio requires proof of vaccination for all employees, staff, and guests. The studio requests all guests to show proof of vaccination upon entering, and notes down the number of individuals who have shown proof and the number of individuals entering the studio to ensure that 95% of them, including children, have shown proof of vaccination.
  • An office that only permits employees in its office area may apply to become a vaccine verified facility after implementing an employer policy requiring proof of vaccination for all employees. If the office has a front desk area accessible to the public, then masks must be worn in that area but the business does not have to require proof of vaccination for individuals entering the front desk area only. If a client visits the office, the business either verifies that the client is vaccinated or brings the client to a space where everyone, including all employees and the client, are masked.
  • A building may apply for certain keyed-only access areas to be a part of the Fully Vaccinated Facilities program. The public-facing areas of the building will still require masks for everyone, including staff, but all individuals within the keyed-only areas (e.g. offices, manufacturing areas, storage areas, etc.) have provided proof of vaccination and may remove their masks once they enter the keyed-only access area.
  • A restaurant may become part of the Fully Vaccinated Facilities program by requiring proof of vaccination from all employees and proof of vaccination for all guests in order to dine indoors. The restaurant may still permit unvaccinated guests to dine outdoors.
  • A community center may designate certain times of day as “vaccine verification periods” and require proof of vaccination during that time of day when masks are not required. Masks are required at all other times of day when the facility is not verifying vaccination status.
  • A house of worship may offer indoor services to fully vaccinated individuals at a certain time of day and masks are not required. The house of worship may offer childcare in a separate room, with all individuals within that childcare room masked, to accommodate childcare needs for its membership and ensure that 95% of those attending the service are vaccinated since children under 12 count towards the number of individuals in the room. The house of worship may still offer fully masked indoor services that don’t require vaccine verification.
  • A recreation center may designate a particular room as a “vaccine verified room.” The recreation center will verify the vaccine status of everyone in that room (for example, by only giving a key or room code to those who have shown proof of vaccination).
  • A gym may designate a class time as a “fully vaccinated class.” The gym will require proof of vaccination in order to attend that class, for example, by only letting members who have provided proof of vaccination to attend that class and coaches who have provided proof of vaccination to coach the class. The gym may offer other classes where proof of vaccination is not required, but all individuals must mask. The gym may also offer outdoor-only classes where no mask or proof of vaccination is required.
  • A membership-based gym or fitness facility may become a Vaccine Verified Facility. The gym or fitness facility must verify that at least 95% of its membership and staff has provided proof of full vaccination. As the gym or fitness facility gets new members and hires new staff, it verifies vaccination status and checks that it is complying with the 95% rule across its membership and staff.
  • A one-time event such as a wedding or party may be hosted as a Vaccine Verified Event if it is ensuring all guests, staff working the event, and others present in the facility provide proof of vaccination status and 95% of the attendees, including staff, children, and others, have provided the proof of full vaccination.
  • A hair salon may offer hours designated as “Vaccine Verified” where the salon verifies vaccination status for all clients and staff and staff and clients can be unmasked. The salon has hours for unvaccinated clientele or clientele who does not wish to share their vaccination status; everyone must wear a mask when vaccine verification is not required.

These examples are illustrative only and each business, organization, and entity should consult legal counsel to determine appropriate policies for their indoor spaces. Boulder County Public Health cannot provide legal advice and these examples do not constitute legal advice.

Applying to Become a Vaccine Verified Facility or Event

The keystone to the application process is a facility’s or event’s vaccination verification policy and the implementation of that policy.

To meet the requirements of this program, the policy must result in at least 95% of the individuals in the indoor space are vaccinated. To calculate the percentage of fully vaccinated individuals in the indoor space, the facility or event must count all individuals indoors, including but not limited to children under 12 and individuals exempt from the vaccine requirement, regardless of the reason.

Facilities and event organizers are advised to consult legal counsel to determine appropriate policies based on their particular circumstances and considering their legal requirements and obligations.

Evaluation of Applications

The Vaccine Verified Facilities program recognizes that each facility and event may have unique needs reflecting the diversity of our community. To be eligible for this program, facilities and events must prove that they are meeting the three requirements below. The program does not require any particular type of written policy nor does it require or prohibit any particular exemptions as long as the facility or event can prove that 95% of the individuals in each approved indoor space has provided proof of full vaccination against COVID-19.

Facilities and events should consult with legal counsel to determine policy compliance with any applicable federal, state, and local laws. Boulder County Public Health cannot and will not review policies for such compliance and cannot provide legal advice to businesses, individuals, or other entities. Businesses, individuals, and event organizers are encouraged to consult with an attorney prior to developing their policies.

All approved Vaccine Verified Facilities and Events are required to demonstrate the following three requirements:

  1. A Written Policy Requiring Proof of Vaccination:
    Each facility and event must have a written policy requiring proof of vaccination for all individuals. If the facility or event permits exemptions, for example, because such exemptions are required by law or due to individuals not yet eligible for the vaccination (i.e. under 12), BCPH recommends that the policy explain the required documentation/information that an individual requesting the exemption must submit, how the facility or event evaluates the applicability of the exemption to that individual, and, if applicable, the unique considerations of the facility or event that require that facility or event to have such an exemption. While such detail is not required under the program, providing the detail about the exemption process may help the facility achieve the 95% requirement. In addition, the policy should address what actions the facility or event will take (for example, denial of entry) for individuals who refuse to comply with the policy.
  2. At least 95% of Individuals Indoors at that Facility or Event Have Provided Proof of Full Vaccination: The policy for each facility and event should result in 100% or nearly 100% of the individuals within the facility or event fully vaccinated against COVID-19. Each facility or event must have verified proof of full vaccination for at least 95% of all individuals within that facility or event. In other words, a maximum of 5% of the individuals at the event or in the facility may be unvaccinated, whether due to an approved exemption, ineligibility for the vaccine, for example, due to age (under 12), or any other reason. Facilities that expect that they may have a large number of individuals requesting exemptions should modify their policy, for example, by providing fully-masked hours of operation. Failure to comply with the 95% rule may result in the facility or event becoming ineligible for the program in violation of Public Health Order 2021-08.
  3. Other Mitigation Strategies, If Necessary: Boulder County Public Health may also consider the facility’s or event’s other mitigation and infection control strategies such as distancing within the indoor space, adequacy of air flow, symptom screening, and testing balanced against other risk factors relative to the indoor space including but not limited to size of indoor space, number of individuals expected in the indoor space as compared to the capacity, the demographics of the event or individuals within the facility (for example, whether the facility or event caters to or expects a large number of higher-risk individuals).

Obtaining Proof of Vaccination

Pursuant to PHO 2021-08, proof of Vaccination means one of the below forms of documentation demonstrating receipt of one course of a single dose COVID-19 vaccine or two doses of any two-dose COVID-19 vaccine plus any subsequent or booster dose of a vaccine as recommended by the Advisory Committee on Immunization Practices (ACIP) in accordance with the recommended timelines:

Facilities and events must verify proof of vaccination with one of the following methods:

  1. COVID-19 Vaccination Record Card (issued by the Department of Health and Human Services Centers for Disease Control & Prevention or WHO Yellow Card) which includes name of person vaccinated, type of vaccine provided, and date last dose administered); OR
  2. A photo of a Vaccination Record Card as a separate document; OR
  3. A photo of the individual’s Vaccination Record Card stored on a phone or electronic device; OR
  4. Documentation of COVID-19 vaccination from a health care provider; OR
  5. Digital record accessed through the myColorado application.

Boulder County Public Health does not require any business, facility, or event to retain any of the identified forms of proof of vaccination records as a condition of this program. Facilities and events should retain records demonstrating compliance with their policy and program requirements.

Fake Vaccine Records

Please familiarize your business, employees, and staff with the FBI’s Public Service Announcement regarding fake vaccine cards.

To report suspicious activity involving fake vaccination cards:

Individuals with Medical, Religious, or Other Exemption Requests

While Boulder County Public Health expects that facilities and events request to verify every individual’s vaccination status, BCPH recognizes that for some facilities and events, an exemption from the fully vaccinated requirement may be required by law, for example, pursuant to Title VII or the Americans with Disabilities Act, or because of ineligibility for the vaccine due to age. In this case, the facility or event may choose whether to admit unvaccinated individuals as long as unvaccinated individuals compromise less than 5% of all individuals in the indoor space. Facilities and events are advised to consult legal counsel about their legal obligations with respect to exemptions.

Facilities and events that have less than 95% of individuals within its indoor space fully vaccinated may risk becoming ineligible for the program, have their program approval revoked, or may be determined to be in violation of Public Health Order 2021-08.

The program does not require any facility or event to provide exemptions to the proof of vaccination requirement. However, if a facility or event permits exemptions from the vaccination requirement then, regardless of the reason for the exemptions, the facility should be able to prove that it has verified that at least 95% of the individuals within its facility or event are fully vaccinated. The calculation of the 95% must include all people in the indoor space, including but not limited to exempt individuals and individuals who are ineligible for the vaccine (i.e. those under 12).

The program requires that you request proof of vaccination for all individuals. The program only permits up to 5% of the individuals within a facility to be unvaccinated, even if those unvaccinated individuals are wearing a mask or otherwise ineligible for the vaccine (for example, under 12).

Facilities and events may permit individuals who will not or cannot provide proof of vaccination in any outdoor setting (e.g. by seating unvaccinated customers outside) or providing certain hours during which any individual (including unvaccinated) may enter the facility as long as all individuals, including vaccinated individuals, are wearing a mask in compliance with PHO 2021-08.

Negative COVID Tests Not an Alternative

A negative test presented in lieu of proof of vaccination as part of a facility policy will not meet the requirements of the vaccine verification program.

Facilities and events may permit individuals who will not or cannot provide proof of vaccination in any outdoor setting (e.g. by seating unvaccinated customers outside) or providing certain hours during which any individual (including unvaccinated) may enter the facility as long as all individuals, including vaccinated individuals, are wearing a mask in compliance with PHO 2021-08.

Children Under 12

Facilities and events may permit children not yet eligible for the vaccine (currently, those under 12) indoors. The facility or event must still meet the requirement that 95% of attendees or individuals within the space have provided proof of vaccination. The facility or event must include the children in the calculation of the 95%. In other words, until a vaccine is approved for those under age 12, facilities must count children under 12 towards the up to 5% of unvaccinated individuals permitted pursuant to the program requirements. However, individuals not eligible for the vaccine and other exempt individuals may be required to wear a mask.

Requirements for Delivery, Repair, & Maintenance

Vaccine Verified Facilities should direct delivery personnel to leave deliveries outside to the extent practicable, and, to the extent such deliveries must be made inside, they should minimize interactions with individuals who have not provided proof of full vaccination. All individuals within the same enclosed area during delivery, repair, or maintenance activities must mask pursuant to PHO 2021-08.

Requirements after Approval as a Fully Vaccinated Facility or Event

Once a facility or event is approved as a Vaccine Verified Facility or Event, it must continue to implement its policy and verify proof of vaccination for all individuals entering its approved indoor space(s). The facility or event may allow individuals to enter the indoor space without a mask. In addition, if the application indicated the event or facility is implementing additional mitigation measures then it must continue to implement those. If Boulder County Public Health conditionally approved the application, the facility or event must implement the conditions of approval.

Required Signs

Approved Vaccine Verified Facilities and Events must post a sign at the door(s) to their indoor spaces indicating that they are an approved vaccine verifying facility or event and that proof of vaccination is required to enter.

A business falsely advertising that they have been approved by Boulder County Public Health when they have not been approved is in violation of Public Health Order 2021-08.

Policy for Refusal to Show Proof of Vaccination

Facilities and businesses should include, as part of their policy development process, a policy for individuals who refuse to comply with that facility or event’s policy, including consequences, such as denial of entry. Boulder County Public Health cannot provide legal advice to facilities or events.

Admitting an individual to your facility or event in violation of your policy will be considered a violation of the program terms and may subject you to penalties under PHO 2021-08.

Unannounced Inspections

Facilities and events that have received approval for the program agree to unannounced inspections by Boulder County Public Health.

Review of Vaccination Proof

This program is based on facility and event policies, not the vaccination status of any individual person, and as a general matter Boulder County Public Health will not inquire into the vaccination status of an individual person for purposes of enforcement. However, Boulder County Public Health may ask to review a facility’s or event’s policy implementation and tracking system to ensure compliance with their policy and program requirements.

Boulder County Public Health may request information on the vaccination status of individuals for purposes of case investigation or contact tracing.

Vaccination Can Help Us Get Back to Normal

Because fully vaccinated individuals have a significantly lower risk of both transmitting and contracting the delta variant COVID-19, Boulder County Public Health is offering additional exceptions to the mask order for facilities and events that implement (and show proof of implementation) of a policy or policies that verify that 95% of all individuals within their public indoor space(s) are fully vaccinated. To be eligible, the event or facility’s policies must result in verification that 95% of all individuals in the public indoor space are vaccinated, including staff, employees, guests, visitors, students (higher Ed), members, clients, children under 12, and any other individual within the designated indoor space at the designated times.

Except as identified under “who can apply,” any event, business, organization, or other entity that requests proof of full vaccination from every individual entering its indoor space may apply to become an Approved Vaccine Verified Facility or Event.

This is a voluntary program designed for businesses, facilities, and events that choose to implement vaccine verification requirements for the indoor spaces. Boulder County’s Vaccine Verified Facility & Event program is flexible. A facility or event may seek approval from Boulder County Public Health in a way that meets their unique business and community needs. Upon receiving approval, the facility or event may allow guests and employees to remove their mask in the approved spaces during the approved times.

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Vaccine Verification Program

Main: 720-776-0822

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