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OCCUPATIONAL EXPOSURE, INJURY, ILLNESS, INCIDENT REPORTING, IMMUNIZATION, AND HEALTH SCREENING POLICY
Website: www.nlupaprogram.com Effective Date: 11/1/2026 Last Reviewed: 11/1/2026 Review Cycle: Annually
Related ARC-PA Standards: A3.09(a), A3.15, B2.16, B2.17, B2.18, B2.19, C1.01, C1.02
I. PURPOSE
The National Louis University (NLU) Physician Assistant (PA) Program is committed to providing a safe educational environment for students participating in classroom instruction, simulation laboratories, community engagement, clinical skills education, and Supervised Clinical Practice Experiences (SCPEs).
This policy establishes requirements and procedures for:
1. Minimum student immunizations and evidence of immunity; 2. Student health screening and clinical health clearance; 3. Infection prevention and occupational health requirements; 4. Reporting, evaluating, treating, documenting, and monitoring occupational injuries, illnesses, and exposures; 5. Prevention and management of exposure to bloodborne pathogens, body fluids, infectious diseases, hazardous chemicals, environmental hazards, and other occupational risks; 6. Return-to-learn and return-to-clinical activities following illness, injury, or exposure; and 7. Ongoing monitoring and continuous quality improvement of student health and safety practices. The policy is designed to protect students, patients, faculty, preceptors, clinical staff, and the public while ensuring compliance with applicable federal and state requirements, current CDC recommendations, NLU policies, clinical-affiliate requirements, and ARC-PA Accreditation Standards.
II. POLICY STATEMENT
All NLU PA students must satisfy applicable immunization, health-screening, infection- prevention, occupational-health, and clinical-site requirements before participating in activities involving patient contact or potential exposure to infectious or hazardous materials.
The Program's requirements are based upon:
• Current recommendations of the Centers for Disease Control and Prevention (CDC); • Recommendations of the CDC Advisory Committee on Immunization Practices (ACIP); • Applicable Illinois statutes and administrative rules; • Applicable federal and local public-health requirements; • NLU institutional requirements; • Requirements established by affiliated clinical sites; and • Occupational risks associated with PA education and clinical practice. The CDC recommends that healthcare organizations establish written occupational infection- prevention policies addressing medical evaluations, infectious-disease screening, immunization programs, exposure and illness management, education and training, and health records. The CDC further recommends that such policies be reviewed and updated as necessary to remain consistent with federal, state, and local requirements.
The NLU PA Program incorporates these principles into its student health and occupational safety requirements.
III. SCOPE
This policy applies to all students enrolled in the NLU PA Program participating in:
Didactic instruction;
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Clinical skills laboratories;
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Simulation activities;
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• Community service sponsored by the Program; • Health fairs; • Interprofessional education activities; • Supervised Clinical Practice Experiences (SCPEs); and • Any other Program-approved educational activity involving patient contact or potential occupational exposure.
The requirements of this policy apply throughout the student's enrollment in the Program and may be supplemented by additional requirements established by individual clinical affiliates.
IV. MINIMUM IMMUNIZATION AND HEALTH-SCREENING REQUIREMENTS
A. General Requirement
Prior to participating in patient-care activities, students must provide documentation demonstrating compliance with NLU PA Program health requirements.
Students must satisfy:
1. Applicable Illinois immunization requirements; 2. Current CDC/ACIP recommendations applicable to healthcare personnel and healthcare students; 3. Applicable NLU requirements; 4. Requirements established by individual clinical affiliates; and 5. Additional requirements resulting from occupational risk, public-health requirements, or an infectious-disease outbreak. Clinical affiliates may establish requirements that are more restrictive than the Program's minimum requirements. Students assigned to such sites must satisfy the clinical affiliate's requirements before beginning the assignment.
The Program may modify requirements when CDC/ACIP recommendations, Illinois requirements, public-health circumstances, or clinical-affiliate requirements change.
V. MINIMUM IMMUNIZATION REQUIREMENTS
The following table establishes the NLU PA Program's minimum immunization and evidence-of- immunity framework.
Immunization / Health Requirement
Minimum NLU PA Program Requirement
Basis
Illinois College Immunization Code; CDC/ACIP
Documentation of required vaccination or acceptable evidence of immunity
Measles (Rubeola)
Illinois College Immunization Code; CDC/ACIP Illinois College Immunization Code; CDC/ACIP
Documentation of required vaccination or acceptable evidence of immunity
Mumps
Documentation of required vaccination or acceptable evidence of immunity
Rubella
Appropriate vaccination history, including Tdap/Td as required to maintain current protection
Illinois requirements; CDC/ACIP
Diphtheria/Tetanus/Pertussis
Documentation of vaccination or acceptable evidence of immunity
CDC/ACIP; clinical- affiliate requirements
Varicella
CDC/ACIP; occupational blood/body-fluid exposure risk; clinical-affiliate requirements CDC/ACIP; clinical- affiliate requirements; applicable Illinois requirements
Completion/documentation of the recommended vaccine series and, when clinically indicated, appropriate evidence of immunity
Hepatitis B
Current seasonal influenza vaccination consistent with CDC recommendations and clinical-affiliate requirements
Influenza
Compliance with current CDC recommendations and applicable clinical-affiliate requirements
CDC/ACIP; clinical- affiliate requirements
COVID-19
Baseline TB risk assessment and screening/testing consistent with CDC recommendations, Illinois requirements, and clinical-affiliate requirements
CDC; Illinois Control of Tuberculosis Code
Tuberculosis (TB)
Illinois College Immunization Code
Required when applicable based upon Illinois student immunization
Meningococcal
requirements, including applicable requirements for students under age 22
Additional vaccines may be required when recommended by CDC/ACIP, required by law, indicated by occupational risk, or required by a clinical affiliate
CDC/ACIP; federal/state requirements; clinical-affiliate requirements
Other vaccines
The Program recognizes that CDC recommendations may change. Therefore, the current CDC/ACIP recommendation applicable at the time of enrollment, clinical assignment, or required renewal will govern when it differs from a prior recommendation. The CDC identifies immunization of healthcare personnel as a critical component of occupational infection prevention because healthcare personnel may be exposed to vaccine- preventable diseases through contact with infectious patients or materials.
VI. ILLINOIS IMMUNIZATION REQUIREMENTS
The NLU PA Program complies with applicable Illinois requirements governing student immunization and health screening.
A. Illinois College Immunization Code
The Illinois College Immunization Code, 77 Ill. Adm. Code Part 694, establishes requirements concerning proof of immunity for students enrolled at covered postsecondary educational institutions.
The Illinois requirements include immunization/evidence-of-immunity provisions concerning:
Measles; Mumps; Rubella;
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•
•
Diphtheria/tetanus/pertussis; and
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• Meningococcal disease for applicable students.
Illinois also establishes requirements for documentation, recordkeeping, and applicable medical, religious, and classification exemptions.
The NLU PA Program will maintain student immunization documentation consistent with applicable NLU and Illinois requirements.
B. Illinois Tuberculosis Requirements
The Illinois Control of Tuberculosis Code, 77 Ill. Adm. Code Part 696, establishes requirements for tuberculosis prevention and control in healthcare settings, including risk assessment and ongoing evaluation of the risk for transmission of tuberculosis.
The NLU PA Program will require baseline TB screening and additional testing or evaluation when indicated by:
Illinois requirements; CDC recommendations;
•
•
A recognized occupational exposure;
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A clinical affiliate;
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Public-health requirements; or An infectious-disease outbreak.
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•
C. Illinois Influenza Requirements
Illinois maintains the Health Care Employee Vaccination Code, 77 Ill. Adm. Code Part 956, concerning influenza vaccination programs in healthcare settings. The rule addresses education and the offering of seasonal influenza vaccination to covered healthcare employees. The Program recognizes that the Illinois Health Care Employee Vaccination Code applies specifically to covered healthcare employees and does not automatically establish an identical statutory requirement for every PA student. Nevertheless, NLU PA students may be required by clinical affiliates to demonstrate current influenza vaccination or satisfy the affiliate's applicable influenza policy before participating in clinical education.
VII. HEALTH SCREENING REQUIREMENTS
In addition to immunization documentation, students must complete health screening appropriate to their anticipated participation in patient-care activities.
At minimum, health screening may include:
1. Health History / Health Inventory
Students may be required to complete a health history or health inventory addressing factors that may affect the student's ability to safely participate in patient-care activities or that may increase the risk of acquiring or transmitting infectious diseases.
2. Evidence of Immunity
Students must provide documentation of immunity to vaccine-preventable diseases when recommended by CDC/ACIP, required by Illinois, or required by a clinical affiliate.
3. Tuberculosis Screening
Students must complete baseline TB risk assessment and testing consistent with CDC recommendations, Illinois requirements, and clinical-affiliate requirements.
4. Infectious-Disease Screening
Additional infectious-disease screening may be required when recommended by the CDC, required by public-health authorities, required by a clinical affiliate, or indicated following an exposure.
5. Medical Evaluation
A student may be required to obtain medical evaluation or clearance when:
• A health condition could affect safe participation in patient-care activities; • The student experiences an occupational injury or exposure; • The student develops an illness that may present a risk to patients or healthcare personnel; • A clinical affiliate requires additional clearance; or • Public-health circumstances warrant additional evaluation.
6. Respiratory Protection / Fit Testing
When required by a clinical affiliate or based upon assigned clinical activities, students may be required to complete respiratory protection evaluation and fit testing.
These provisions reflect CDC recommendations for preplacement, periodic, and episodic medical evaluations, including health assessments, screening, diagnostic testing, immunization services, exposure and illness management, and evaluation of evidence of immunity.
VIII. HEALTH CLEARANCE PRIOR TO CLINICAL PARTICIPATION
Students must satisfy applicable health-clearance requirements before participating in SCPEs and other patient-care activities.
Clinical clearance may include documentation of:
Required immunizations; Evidence of immunity;
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•
TB screening;
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• Required infectious-disease screening; • Health history/health inventory; • Required physical or medical clearance; • Annual influenza vaccination when required; • COVID-19 requirements when applicable; • Clinical-site-specific requirements; • Required occupational-health training; and • Other documentation specified by the clinical affiliate.
A student who does not satisfy applicable health-clearance requirements may not participate in the affected clinical activity until the requirements have been completed or an approved exception has been documented.
IX. EXEMPTIONS AND ACCOMMODATIONS
The Program will consider requests for medical exemptions and other legally recognized exemptions consistent with applicable federal and state law, NLU policy, and clinical-affiliate requirements.
An exemption from a particular vaccination or health requirement does not automatically guarantee that the student can be placed at every clinical site.
When an exemption is granted or recognized, the Program and/or clinical affiliate may establish additional precautions or alternative requirements when permitted by law and necessary to protect patients, students, and healthcare personnel.
Students are responsible for providing appropriate documentation supporting an exemption when required.
X. CLINICAL-AFFILIATE REQUIREMENTS
Clinical affiliates may impose health, immunization, screening, training, or occupational-health requirements that exceed the Program's minimum requirements.
Examples may include:
Additional vaccination requirements;
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Additional TB screening;
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• Additional infectious-disease screening; • Annual influenza vaccination; • COVID-19 vaccination or documentation; • Respirator fit testing; • Drug screening; • Background screening; • Physical examination or medical clearance; • Additional occupational-health documentation; or • Site-specific infection-prevention training.
Students must satisfy the requirements of the assigned clinical affiliate before beginning the applicable clinical experience.
The Program will communicate applicable clinical-site requirements to students in advance when reasonably possible.
XI. PREVENTION AND REQUIRED TRAINING
Prior to participating in any patient-care activity, students must successfully complete required educational programs regarding occupational health and safety.
Required training includes:
• OSHA Bloodborne Pathogens Standard; • Standard Precautions; • Transmission-Based Precautions; • Infection Prevention; • Personal Protective Equipment (PPE); • Needle Safety;
Exposure Control Procedures; Hazard Communication; Clinical Incident Reporting;
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•
•
HIPAA; and
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Clinical Site Safety Orientation.
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These educational sessions are mandatory and are completed during Program orientation and before students begin clinical education experiences.
Students who fail to complete required training may not participate in laboratory activities, simulation, or SCPEs until all requirements have been satisfied.
The CDC recommends education and training addressing modes of infectious-disease transmission, Standard and Transmission-Based Precautions, hand hygiene, sharps injury prevention, immunizations, infectious-disease screening, access to occupational-health services, and reporting of exposures and illnesses.
XII. STUDENT RESPONSIBILITIES
Students are responsible for:
1. Maintaining required immunizations and health-clearance documentation; 2. Completing required health screening; 3. Following Standard Precautions at all times; 4. Using appropriate PPE; 5. Complying with CDC, OSHA, NLU, and clinical-affiliate infection-prevention policies; 6. Reporting occupational injuries and exposures immediately; 7. Reporting illnesses when required by Program or clinical-site policy; 8. Completing required incident documentation; 9. Following medical recommendations provided by the treating healthcare provider; 10. Participating in required follow-up evaluation and treatment; 11. Maintaining current health-clearance documentation throughout enrollment; and 12. Notifying the Program when a clinical-site health requirement cannot be satisfied.
XIII. OCCUPATIONAL EXPOSURE, INJURY, OR ILLNESS
Students who sustain an occupational injury, illness, or exposure to bloodborne pathogens, body fluids, infectious diseases, hazardous chemicals, environmental hazards, or other occupational
risks while participating in Program activities shall immediately report the incident and seek appropriate medical evaluation.
Examples include, but are not limited to:
Needlestick injuries;
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Sharps injuries;
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Blood or body-fluid exposure; Mucous-membrane exposure; Exposure involving non-intact skin;
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•
•
• Airborne infectious-disease exposure; • Chemical exposure; • Hazardous medication exposure; • Radiation exposure; • Musculoskeletal injuries; • Falls; • Patient-related injuries; • Workplace violence or assault; and • Environmental injuries occurring during educational activities.
Students shall receive evaluation and treatment according to the policies of the affiliated clinical site or, when necessary, the nearest appropriate emergency medical facility.
Nothing in this policy supersedes emergency medical treatment.
XIV. IMMEDIATE RESPONSE FOLLOWING EXPOSURE OR INJURY
Step 1 — Immediate First Aid
Immediately stop the activity and perform appropriate first aid.
Examples include:
• Washing needlestick or sharps injuries with soap and water; • Flushing mucous-membrane exposures with water; • Irrigating eye exposures; and • Following affiliate-specific exposure procedures.
Step 2 — Notify Appropriate Personnel
Immediately notify:
Supervising Preceptor;
•
• Clinical Site Supervisor, when applicable; • Clinical Director of Education or designee; and • Course Faculty, when applicable.
Notification should occur as soon as safely possible following the incident.
Step 3 — Seek Medical Evaluation
Seek immediate medical evaluation through:
• Clinical affiliate Employee/Occupational Health Office; • Emergency Department; • Urgent Care Center; or • Other designated healthcare provider identified by the clinical affiliate.
Students shall follow all applicable clinical-affiliate exposure protocols.
XV. INCIDENT DOCUMENTATION
Students shall complete:
• National Louis University Incident Report Form; • Clinical Affiliate Incident Report, when required; and • Employee/Occupational Health documentation, when applicable.
Documentation should include:
Date and time of incident;
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Location;
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Nature of exposure or injury;
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• Circumstances surrounding the incident; • PPE utilized or not utilized; • Student Hepatitis B immunization status; • Relevant immunization history; • Tetanus immunization status;
• Source-patient information, when permitted by law and affiliate policy; • Medical evaluation completed; and • Recommended follow-up from the treating healthcare provider.
The NLU Incident Report Form is available through the University's reporting system:
https://cm.maxient.com/reportingform.php?NationalLouisUniv&layout_id=1
Documentation shall be maintained in accordance with University policy, applicable privacy laws, and clinical-affiliate requirements.
XVI. MEDICAL FOLLOW-UP
Students shall comply with recommendations provided by the treating healthcare provider.
When indicated, follow-up may include:
Laboratory testing;
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Post-exposure prophylaxis;
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Vaccination;
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Medical monitoring;
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Infectious-disease consultation;
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• Occupational-medicine evaluation; and • Temporary work or clinical restrictions.
Students must provide documentation verifying medical clearance before returning to educational activities when requested by the Program or clinical affiliate.
XVII. STUDENTS ASSIGNED TO DISTANT OR REMOTE CLINICAL SITES
Students assigned to remote or distant clinical sites shall follow the emergency procedures established by the clinical affiliate.
In emergency situations, students shall:
1. Seek immediate emergency medical care;
2. Notify the supervising preceptor; 3. Notify the Clinical Director of Education as soon as practical; and 4. Submit discharge instructions and medical documentation within one business day whenever possible. The Clinical Director of Education shall review documentation and determine whether additional evaluation or medical clearance is necessary before the student's return to educational or clinical activities.
XVIII. RETURN-TO-LEARN / RETURN-TO-CLINICAL PROCESS
Students may return to educational or clinical activities when:
• Medically cleared by the treating healthcare provider, when required; • Clinical restrictions have been reviewed; • Program leadership determines participation is appropriate; and • Clinical-affiliate requirements have been satisfied.
The Program may require additional documentation before permitting return to SCPEs.
XIX. CONFIDENTIALITY OF HEALTH INFORMATION
All health information obtained through health screening, immunization documentation, occupational injury, illness, or exposure shall be maintained confidentially in accordance with:
FERPA;
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HIPAA, when applicable;
•
Applicable state and federal law; and National Louis University policies.
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•
Medical information shall be shared only with individuals having a legitimate educational, clinical, safety, or occupational need to know.
Health records will be maintained in accordance with applicable University and clinical-affiliate requirements.
XX. FINANCIAL RESPONSIBILITY
Students are responsible for healthcare expenses incurred following occupational injury or illness unless otherwise covered by:
Clinical-affiliate policy;
•
• Workers' compensation, when applicable; • Student health insurance; or • Other available insurance coverage.
Students are strongly encouraged to maintain comprehensive health insurance throughout enrollment in the PA Program.
XXI. POLICY AVAILABILITY
The NLU PA Program shall make this policy readily available to prospective and current students.
The policy will be:
1. Published on the NLU PA Program website; 2. Included or referenced in applicable PA Program student handbooks; 3. Included or referenced in clinical education materials; 4. Communicated during new-student orientation; 5. Available through the University's student portal or learning-management system, as applicable; 6. Communicated to students before participation in clinical education; and 7. Updated and redistributed when substantive changes are made.
The Program will provide students with reasonable notice of changes to immunization, health- screening, or clinical-clearance requirements whenever practicable.
XXII. CDC AND REGULATORY REFERENCES
The NLU PA Program uses the following authoritative resources in maintaining this policy:
Centers for Disease Control and Prevention
CDC Infection Control for Healthcare Professionals: https://www.cdc.gov/infection-control/hcp/index.html
CDC Infection Control in Healthcare Personnel — Summary of Recommendations: https://www.cdc.gov/infection-control/hcp/healthcare-personnel-infrastructure-routine- practices/summary-recommendations.html CDC Immunization Programs for Healthcare Personnel: https://www.cdc.gov/infection-control/hcp/healthcare-personnel-infrastructure-routine- practices/immunization-programs.html
CDC Core Infection Prevention and Control Practices: https://www.cdc.gov/infection-control/hcp/core-practices/
CDC Medical Evaluations: https://www.cdc.gov/infection-control/hcp/healthcare-personnel-infrastructure-routine- practices/medical-evaluations.html CDC Occupational Infection Prevention and Control Education and Training: https://www.cdc.gov/infection-control/hcp/healthcare-personnel-infrastructure-routine- practices/occupational-training.html
Illinois
77 Ill. Adm. Code Part 694 — College Immunization Code: https://www.ilga.gov/agencies/JCAR/EntirePart?titlepart=07700694
77 Ill. Adm. Code Part 696 — Control of Tuberculosis Code: https://www.ilga.gov/agencies/JCAR/EntirePart?titlepart=07700696
77 Ill. Adm. Code Part 956 — Health Care Employee Vaccination Code: https://www.ilga.gov/agencies/JCAR/EntirePart?titlepart=07700956
The Program will monitor these resources and other applicable authoritative sources for changes that may affect student health requirements.
XXIII. CONTINUOUS QUALITY IMPROVEMENT
This policy shall be reviewed at least annually by the:
Clinical Education Committee;
•
• Student Evaluation and Progress Committee; and • PA Faculty and Staff Committee.
Assessment data may include:
Immunization compliance rates; Health-clearance completion rates;
•
•
TB-screening compliance;
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• Bloodborne-pathogen training completion; • Occupational incident reports; • Exposure reports; • OSHA compliance; • Clinical-affiliate feedback; • Student evaluations; • Exposure trends; • Infection-prevention training completion; • Clinical-site health-clearance issues; and • Annual safety audits.
The Program will monitor compliance with applicable CDC/ACIP recommendations, Illinois requirements, NLU requirements, and clinical-affiliate requirements.
The CDC recommends performance measurement and continuous quality improvement for occupational infection-prevention programs, including monitoring evidence of immunity and vaccination coverage and periodically assessing the effectiveness of occupational infection- prevention services. Recommendations resulting from policy review will be incorporated into the Program's Continuous Quality Improvement (CQI) process and documented within the Annual Program Effectiveness Report consistent with ARC-PA Standards C1.01 and C1.02.
XXIV. ARC-PA ALIGNMENT
This policy directly supports the NLU PA Program's compliance with applicable ARC-PA 6th Edition Standards, including:
• A3.09(a) — Minimum immunization and health screening of students; • A3.15 — Student health and safety; • B2.16 — Clinical education/student safety; • B2.17 — Occupational exposure;
• B2.18 — Clinical education health requirements; • B2.19 — Clinical site responsibilities; • C1.01 — Programmatic assessment; and • C1.02 — Continuous quality improvement.
The policy provides evidence that the NLU PA Program:
1. Establishes minimum immunization and health-screening requirements; 2. Bases those requirements upon current CDC/ACIP recommendations;
3. Complies with applicable Illinois requirements; 4. Incorporates clinical-affiliate requirements;
5. Applies health-clearance requirements before clinical participation; 6. Provides infection-prevention and occupational-health education; 7. Establishes procedures for occupational exposure and illness; 8. Protects confidentiality of student health information; 9. Makes the policy available to prospective and current students; and 10. Reviews and updates the policy through an established CQI process.
XXV. DEFINITIONS
CDC: Centers for Disease Control and Prevention.
ACIP: Advisory Committee on Immunization Practices.
Clinical Affiliate: An external healthcare organization or clinical practice site with which NLU has an approved clinical education relationship.
Health Clearance: Documentation demonstrating that a student has satisfied applicable immunization, screening, medical, training, and clinical-site requirements necessary to participate in patient-care activities. Occupational Exposure: Reasonably anticipated skin, eye, mucous membrane, parenteral, or other contact with blood, body fluids, infectious materials, hazardous substances, or other occupational hazards that may result from participation in educational or clinical activities.
SCPE: Supervised Clinical Practice Experience.
Standard Precautions: Infection-prevention practices applied to all patient care based on the principle that all blood, body fluids, non-intact skin, and mucous membranes may contain transmissible infectious agents.
Transmission-Based Precautions: Infection-prevention precautions used in addition to Standard Precautions for patients who are known or suspected to be infected or colonized with certain infectious agents.
XXVI. INCIDENT REPORT FORM
Students shall use the University's designated Incident Report Form for reporting applicable incidents:
https://cm.maxient.com/reportingform.php?NationalLouisUniv&layout_id=1
For assistance with completing the form, students may contact the designated NLU student- support office identified in current University procedures.
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