San Franciso. New York. New Orleans. It’s only a matter of time before more U.S. cities follow suit in requiring members to show proof of COVID-19 vaccinations to enter fitness facilities.
To help you put a process in place — and put your mind at ease — we’ve gathered our most commonly-asked questions related to HIPAA, along with recommendations on tracking COVID-19 vaccinations in Member Manager software.
COVID-19 Proof of Vaccination FAQs
Are we allowed to ask for proof of vaccination status?
From a HIPAA law perspective, as a business owner, you are allowed to ask for this information. This does not mean that your members must provide this. However, there could be state or local laws that may differ on this. Please seek legal guidance on this for your location.
Is it a HIPAA violation to request this information of a member?
It is not a violation to request this. “It is not a HIPAA violation to ask someone their vaccine status,” said Kayte Spector-Bagdady, who helps direct the University of Michigan’s Center for Bioethics & Social Sciences in Medicine. “HIPAA applies in many fewer circumstances than people think.” HIPAA, or the Health Insurance Portability and Accountability Act, protects people’s private health information from being shared by certain health care entities without patient consent.
Is my club subject to HIPAA laws?
This depends on your business model. If you are not a HIPAA-covered entity, then the laws do not apply. Here’s who HIPAA regulates:
Health insurance companies, Medicare, Medicaid, or employers who run self-funded health plans
Business associates, such as health care providers, hospitals, nursing homes, or anyone actually delivering a health care service
Subcontractors of business associates, such as health care clearinghouses or billing companies that may transfer patient data
If your club has established a relationship with a HIPAA-covered entity and you signed a HIPAA Business Associate Agreement, you will need to get proper HIPAA legal counsel to determine what options you have to recording and storing members’ vaccination status.
Are there other laws regarding this that I could be subject to?
Many states and localities have introduced bills regulating the use of vaccination passports and mandates for business owners of their guests. You will want to consider these as you make decisions for your members.
COVID-19 Vaccination Tracking Recommendations Using Member Manager Software
IMPORTANT! Many states and localities have introduced bills regulating the use of vaccination passports and mandates for business owners of their guests. You should become familiar with your state, county, and local city laws before implementing this tracking process to ensure you remain in compliance.
If your facility is planning to track members that have provided proof of the COVID-19 vaccination, we recommend using the Questionnaires feature in the Member Manager software, in conjunction with the Questionnaire Alerts.
How to Create a Questionnaire in Member Manager Software
1. Go to Setup > Personalize > Questionnaires > Add Questionnaire
2. Enter a Name for your questionnaire
3. Select whether the questionnaire will be a “Mandatory questionnaire
4. Select whether the questionnaire will be Tagged to Self Registration, which means that members who self-register themselves will have to complete the questionnaire.
5. Select whether Digital Acceptance is required.
Next, to begin building your questionnaire, choose either Add Text Field, add a Question with Text Answer or a Question with a YES | NO response.
You can also select whether each specific question is mandatory using the corresponding drop-down menu.
How to Activate a Questionnaire Alert in Member Manager Software
Member Manager software allows you to set up Alerts that will display to members when checking in, or to staff members when viewing a member’s profile or booking a member into a class.
To configure these Alerts, go to Setup > Alerts.
From here, you can choose to display alerts to all staff, all members, or configure alerts for individual staff members using the Instructor drop-down menu.
Next, select “On” next to Questionnaires, then click Save.
Get Your Business Running Like Clockwork with Member Manager Software
“100% of our in-house and external business is handled through Member Manager software. If you’re serious about operating a successful service-based business, especially a martial arts school, you need to get Member Manager software.”
— Ben Nease, Bitanga’s Martial Arts Center