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Employer Mandated COVID 19 Vaccinations

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On Thursday, September 9th, President Biden unveiled plans to create Federal rules regarding vaccine mandates. While little is known at this time about the specifics of the rule – here’s what we do know. There are four categories of Employers that this rule will apply to:

1. Federal Employees & Contractors:

  • Expected Requirements: All federal worders & contractors will be required to have the COVID 19 vaccination, eliminating the option for regular testing.
  • Exemptions: Limited Exemptions for religious & medical reasons
  • Timeline: Approx. 75 days

2. Employers with over 100 Employees:

  • Expected Requirements: Employees are required to either be fully vaccinated OR submit to weekly testing. This will be enforced by OSHA. Employers are required to give employees paid time off to get themselves & family members vaccinated
  • Exemptions: Limited Exemptions for religious & medical reasons
  • Timeline: Unknown

3. Healthcare Workers that receive Medicaid or Medicare Funds:

  • Expected Requirements: All workers in hospitals or other healthcare settings that receive funds from Medicare or Medicaid will be required to have the COVID 19 vaccination, eliminating the option for regular testing.
  • Exemptions: Limited Exemptions for religious & medical reasons
  • Timeline: Unknown

4. Teachers & Staff at Head Start and other Federally Funded Educational Settings:

  • Expected Requirements: All workers in Head Start or other federally funded education settings will be required to have the COVID 19 vaccination, eliminating the option for regular testing.
  • Exemptions: Limited Exemptions for religious & medical reasons
  • Timeline: Unknown

While we don’t know the details of this forth-coming rule yet, it is important to start thinking about how you will implement it. Some items to consider:

  • If the employer is required to pay for testing for those employees who opt for that strategy, how will that impact your budget?
  • Who will write your company’s policy, and disseminate that to employees?
  • Who in your organization will be the person to track and follow up on vaccination status?
  • Who will manage the regular testing for employees who opt for that strategy?
  • How will you store the protected medical information of your employees? An internal policy should be adopted.

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