The below list is intended to assist you in deciding how your company will comply with the Biden Vaccine Mandate. This list is not intended to be comprehensive.
All employers who have 100 or more employees should:
(1) Adopt procedures for determining employees’ vaccination status. The EEOC has made it clear you may inquire if your employees are vaccinated against COVID-19, but this information must be kept confidential.
(2) Determine what percentage of your work force is already vaccinated.
(3) Determine if you will mandate the vaccine or if you will allow employees to be tested weekly.
(4) Have a plan to administer the weekly test.
- If planning for weekly testing, determine the logistics of how, where and when you will require your work force to be tested.
- Will you use onsite testing or vendors?
- Will you pay your employees for the time it takes to be tested?
(5) Have a plan for tracking the test results.
- Who will collect the test results?
- Where will the results be stored?
- What should managers do if an employee tests positive?
(6) Develop a plan for handling vaccine accommodation requests.
- Develop a reasonable accommodation policy.
- Develop a reasonable accommodation request form.
(7) Develop a plan for addressing noncompliance by employees.
- What disciplinary action, if any, will you take if an employee does not get tested?
- What happens to an employee who refuses to get vaccinated and does not get tested weekly?
(8) Prepare for OSHA complaints and inspections.
(9) Implement a COVID-19 policy.
Please contact an MBA HR Consultant at 727-563-1500 if you have questions or concerns about these recommendations.