Pfizer’s COVID vaccine has been fully approved by the FDA and no longer carries the “Emergency Use” label. Many employers may now feel empowered to proceed to requiring their employees become vaccinated as a condition of employment. Many employers may also see the legal risks of such a condition diminishing.
If you plan to require vaccinations at your organization, below are ten steps worth considering:
- Ensure that your board members are fully committed to this action.
- Think long and hard about how this mandate will be received and not just by your employees. What about those whom you serve? Your funders and the community within which you operate.
- Think about developing a vaccine team for coordinating the process. All team members should be confidential with information they may learn and/or encounter.
- Draft a cohesive, legally reviewed policy which includes timelines for acceptance, adherence, and a policy and practice to deal with those employees who refuse. Develop a system for tracking compliance and who will have access to this information.
- Be clear, concise, and consistent with any policy and process you develop.
- Absolutely, positively, be consistent in following your policies with all staff.
- Consider compensation issues that may come up. Will you reimburse costs like mileage and time spent obtaining the vaccine? Don’t forget that some people have strong physical reactions to receiving the vaccine. Know how you will accommodate the time off that may be needed.
- Be prepared for pushback and anxiety from all levels.
- Have an action plan for the pushback and ensure that all members of your management team have the same response.
- Establish a very clear and reasonable policy addressing accommodations that need to be made for religious and medical exemptions. Take care to be consistent and cautious with each employee who requests an accommodation. The ADA should be top of mind. Tread carefully.
COVID has kept HR (and the world) on its toes for the last 19 months. Information is gained, laws and legislation are written and enacted. It is vital to ensure your policies comply with all state and federal workplace laws. This is a time to have licensed legal counsel review your policies for compliance. Think of your policies and procedures as a living, breathing document.
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The information contained in this article is not a substitute for legal advice or counsel and has been pulled from multiple sources.
