The purpose of this memorandum is to inform Massachusetts Licensed Ambulance Services and EFR Services of the steps needed to fulfill the Massachusetts Department of Public Health (DPH) requirement to vaccinate healthcare personnel (HCP) for influenza and SARS-CoV-2(COVID-19) and to report data in accordance with DPH guidelines outlined in this memorandum.
COVID-19 and Influenza Vaccination Requirement:
As a condition of licensure, under 105 CMR 170.341 and 170.342 DPH licensed ambulance services and EFR Services regulations require licensed ambulance services to ensure all HCP are vaccinated annually with seasonal influenza vaccine and are up to date with vaccine doses for COVID-19 as recommended by the Centers for Disease Control and Prevention (CDC), unless an individual is exempt from vaccination. On September 17, 2025, DPH, in alignment with the Northeast Public Health Collaboration, issued recommendations regarding COVID-19 vaccinations available here: https://www.mass.gov/info-details/dph-recommended-guidance-for-vaccines. Based on clinical evidence and in alignment with the Northeast Public Health Collaboration and CDC recommendations, being up to date with vaccine doses for COVID-19 means that all HCP must receive one 2025-2026 COVID-19 vaccine.
HCP means any individual or individuals who either work at or come to the licensed service or site or EMS vehicle and who are employed by or affiliated with the service, whether directly, by contract with another entity, or as an independent contractor, paid or unpaid including, but not limited to, employees, members of the medical staff, contract employees or staff, students, and volunteers, whether or not such individual(s) provide direct care.
Vaccination of HCP is an important component of the strategy to protect Massachusetts residents from morbidity and mortality from respiratory infections including influenza and COVID-19. Vaccinated healthcare workers are less likely to transmit SARS-CoV-2 to vulnerable residents. HCP are also at higher risk of exposure and infection with SARS-CoV-2. Prevention of both influenza and COVID-19 in HCP is vital to maintaining healthcare capacity and protecting the residents they care for.
All HCP, who are not subject to an exemption, must receive a 2025-2026 COVID-19 vaccine no later than March 31, 2026. In alignment with the CDC and the Centers for Medicare and Medicare Care Services (CMS), all HCP, who are not subject to an exemption, must have received the 2025-2026 seasonal influenza vaccine no later than March 31, 2026. While ambulance services are not required to procure vaccines for, or administer vaccines to their HCP directly, they are required to ensure that HCP are vaccinated, unless exempt, in accordance with these guidelines. Ambulance services may choose to host a health care provider to administer vaccine to their HCP and may bill health insurance for those HCP that provide their insurance information. Additionally, ambulance services may direct HCP to a local pharmacy or health care provider for the administration of these vaccines.
For HCP subject to the vaccine exemption, ambulance services must require that such individual take mitigation measures in addition to continuing to self-assess for any signs or symptoms of illness. Mitigation measures that the ambulance services can require exempt HCP take include, but are not limited to:
- Wearing a facemask during all patient care encounters for the duration of the respiratory illness season; and
- Avoiding direct patient care.
DPH continues to recommend that HCP use personal protective equipment (PPE) consistent with the Department’s Comprehensive PPE Guidance.
Documentation Requirements:
The EMS System regulations direct that ambulance services require and maintain for each individual proof of current seasonal influenza vaccination and COVID-19 vaccination or the HCP’s exemption statement. These records must be maintained via a central system to track the vaccination status of all HCP and must be available to DPH upon request. Examples of individual proof of current vaccination include but are not limited to:
- Copy of CDC Vaccination Card.
- Copy of MA Immunization Information System (MIIS) Vaccination Record.
- Copy of vaccination from an electronic health record.
- COVID-19 SmartHealthcard from the Commonwealth’s MyVaxRecords public portal.
Exemption statements from HCP must include a signed statement certifying they received information about the risks and benefits of COVID-19 and/or influenza vaccination.
Reporting Requirements:
To comply with the EMS System regulations, all Massachusetts ambulance services must annually report their aggregate HCP COVID-19 and influenza data to DPH via REDCap. The link may be found here: https://redcap.link/ma-hcp-covidandfluvaccination
- Only reports submitted through REDCap will be accepted.
- Each licensed ambulance service is required to report the following no later than May 15, 2026:
- Number of HCP who worked at the ambulance service for at least 1 day between October 1, 2025 and March 31, 2026.
- Number of HCP who received the updated 2025-2026 influenza vaccine as of March 31, 2026.
- Number of HCP who are exempt from the influenza vaccine (unvaccinated at time of reporting).
- Number of HCP who received an updated 2025-2026 COVID-19 vaccine as of March 31, 2026.
- Number of HCP who are exempt from the updated COVID-19 vaccine (unvaccinated at time of reporting).
Please note that the EMS System regulations do not allow for reporting an unknown vaccination status.
To assist ambulance services in documenting, monitoring and tracking HCP COVID-19 & influenza vaccination data throughout the respiratory season, DPH has developed a Facility COVID-19 & Flu Tracking Tool, available at the following link: Health Care Personnel Influenza Vaccination References and Resources | Mass.gov
Please submit questions regarding the reporting and data submission requirements to the Bureau of Health Care Safety and Quality at dhcq.fludata@state.ma.us.