Making COVID-19 vaccination part of your workplace wellness program may offer benefits to you and your employees. To aid in keeping their workplace healthy, employers can consider offering free, on-site COVID-19 vaccinations at work locations.

This HR Insights article provides an overview of guidance from the Centers for Disease Control and Prevention (CDC) for workplace vaccination programs. As of this writing, vaccine programs are not yet available to many employers, depending on the type of organization and guidance from local officials. However, vaccination programs will extend to additional workplaces as vaccine availability increases, meaning that employers should begin planning accordingly. Employers should continue to monitor CDC guidance and follow direction from local health officials.

Providing COVID-19 Vaccines to Your Employees

Some workplaces may be able to offer a COVID-19 vaccination program on-site. However, if your organization can’t offer COVID-19 vaccinations on-site, or if your state or jurisdiction has determined that your organization is not a suitable location at this time, you can encourage employees to seek COVID-19 vaccination in their community and provide them with information about where they can get the vaccine.

COVID-19 Vaccination Program Benefits

Vaccination programs can offer benefits to workplaces. For employers, these potential benefits include:

• Improved workforce health by helping prevent employees from getting COVID-19
• Reduced absences due to illness
• Reduced time missed from work to get vaccinated
• Improved productivity
• Improved morale

For employees, potential benefits include:

• Prevented COVID-19 illness
• Reduced absences and doctor visits due to illness
• Offered convenience
• Improved morale

Implementing a Workplace COVID-19 Vaccination Program

Employers considering implementing a workplace COVID-19 vaccination program should contact the health department in their jurisdiction for guidance. The planning process for hosting a workplace COVID-19 vaccination program should include input from management, HR, employees and labor representatives, as appropriate. Important preliminary steps include obtaining senior management support, identifying a vaccine coordinator, and enlisting expertise from local public health authorities, occupational health providers and pharmacies.

Provide COVID-19 Vaccine Information to Vaccine Recipients

COVID-19 vaccines will initially be available through the U.S. COVID-19 Vaccination Program. The law requires that vaccination providers participating in the program provide vaccine recipients with certain information, including an EUA Fact Sheet for Recipients about the vaccine they are receiving and possible side effects, as well as a vaccination record card with the name and manufacturer of the vaccine they received, where they received it and when they need to return for a second dose of the vaccine, if required. Providers can also hand out this flyer from the CDC.

Encourage Employees to Get Vaccinated

Consider hosting a vaccination clinic at your workplace, and contact the health department in your jurisdiction for guidance. If eligible, offer the vaccination at no charge and during work hours.

If hosting a vaccination clinic at your workplace is not possible, consider other steps to encourage vaccination, listed below:

  • Be flexible in your HR policies. Establish policies that allow employees to take paid leave to seek COVID-19 vaccination in the community. Support transportation to off-site vaccination clinics.
  • Use promotional posters/flyers to advertise locations offering COVID-19 vaccination in the community. Display posters about COVID-19 vaccination in break rooms, cafeterias and other high-traffic areas.
  • Post articles in company communications (e.g., newsletters, intranet, emails and portals) about the importance of COVID-19 vaccination and where to get the vaccine in the community.

Learn more about how to get started communicating about and promoting COVID-19 vaccines in your workplace.

Be Prepared to Answer Common Questions

Employers should be prepared to answer common COVID-19 vaccine questions that employees may have. Common questions include:

  • Will I be required to get vaccinated for work?
  • Are COVID-19 vaccines safe?
  • Do I need to wear a mask and avoid close contact with others after I am vaccinated?
  • How can I report vaccine side effects?
  • Do I still need a vaccine if I already had COVID-19?
  • How will I remember to get my second shot?

The CDC offers resources for how to answer these and other questions regarding COVID-19 vaccines.

Vaccine Scheduling

Consider staggering employee vaccination schedules to avoid worker shortages due to vaccine side effects. Data from COVID-19 vaccine trials indicates that most side effects are mild. Most occur within the first three days of vaccination (the day of vaccination and the following two days, with most occurring the day after vaccination), resolve within one to two days, and are more frequent and severe following the second dose. At this time, we do not know how common these symptoms may be among employees. Nonetheless, we expect that most employees who experience symptoms following vaccination will not need to miss work.
However, some employees who get vaccinated may have side effects, like fever, and might need to miss work temporarily. The CDC understands concerns about potential workforce shortages resulting from vaccine side effects. Workplaces may consider staggering schedules for employees who receive vaccination so that not all employees are vaccinated on the same day.

In addition, staggering may be more important for the second dose, after which side effects seem more frequent. To help ensure continuity of operations, facilities may consider staggering vaccination for employees in the same job category or who work in the same area of a facility. Staggering vaccination for employees may cause delays, and the decision to stagger vaccination will need to be weighed against potential inconveniences that might reduce vaccine acceptance. Facilities should evaluate their specific situations when determining their best approach. Facilities that choose to stagger vaccine administration should also ensure all employees receive two doses as recommended.

Vaccinations for Contractors and Temporary Employees

For workers employed by contract firms or temporary help agencies, the staffing agency and the host employer are joint employers and, therefore, both are responsible for providing and maintaining a safe work environment. The extent of the responsibilities the staffing agency and the host employer have will vary, depending on the workplace conditions, and should be described in their contract. The Occupational Safety and Health Administration (OSHA) and the National Institute for Occupational Safety and Health (NIOSH) has issued guidance on Protecting Temporary Workers.

If you plan to offer vaccination on-site, consider providing vaccination to all people working at the workplace, regardless of their status as a contract or temporary employee. What is most important is to encourage everyone at the worksite to be vaccinated, no matter what their work arrangement is. If you do not plan to or are unable to offer worksite vaccination, consider providing information to those at the workplace about how to explore options for vaccination in the community.

If Employees Develop a Fever After Vaccination

Employees who experience a fever after vaccination should, ideally, stay home from work pending further evaluation, including consideration for COVID-19 testing. The CDC has released guidance, which includes suggested approaches to evaluating and managing post-vaccination symptoms, including fever.

When Employees Should Call Their Doctor

In most cases, discomfort from fever or pain at the injection site after vaccination is normal and lasts only a day or two. You should encourage the employee to stay home and contact their doctor or health care provider if:

  • The redness or tenderness where they got the shot increases after 24 hours.
  • Their side effects are worrying them or do not seem to be going away after a few days.

Learn about how a problem or bad reaction can be reported after getting a COVID-19 vaccine.

Vaccine Mandates & Exemptions

COVID-19 vaccines are not mandated under Emergency Use Authorizations (EUAs). However, whether a state, local government or employer, for example, may require or mandate COVID-19 vaccination is a matter of state or other applicable law.

Employer Vaccine Mandates and Proof of Vaccination

A mandatory vaccination policy may require employees to provide proof that they have received a COVID-19 vaccination from a pharmacy or their own health care provider. However, the employer cannot mandate that the employee provide any medical information as part of the proof.

Employee Medical Conditions or Religious Beliefs Exemptions

Two types of exemptions can be implemented:

  • Medical exemptions—Some people may be at risk for an adverse reaction because of an allergy to one of the vaccine components or a medical condition. This is referred to as a medical exemption.
  • Religious exemptions—Some people may decline vaccination because of a religious belief. This is referred to as a religious exemption.

Employers offering vaccination to workers should keep a record of the offer to vaccinate and the employee’s decision to accept or decline vaccination.

Guidance on Exemptions

The Equal Employment Opportunity Commission (EEOC) provides guidance on mandatory vaccination against H1N1 influenza. The EEOC guidance may be applicable to COVID-19 vaccination, which became available in December 2020.

For employers covered by the Americans with Disabilities Act (ADA), “… an employee may be entitled to an exemption based on an ADA disability that prevents him from taking the influenza vaccine.”

For employers covered under Title VII of the Civil Rights Act of 1964, “once an employer receives notice that an employee’s sincerely held religious belief, practice, or observance prevents him from taking the influenza vaccine, the employer must provide a reasonable accommodation unless it would pose an undue hardship.”

According to the guidance, “Generally, ADA-covered employers should consider simply encouraging employees to get the influenza vaccine rather than requiring them to take it.”

For More Information

The recommendations provided in this article should not be considered legal advice. Employers should consult with local legal counsel for legal advice. Employers should continue to monitor current guidance from the CDC on workplace vaccination programs and follow recommendations from local health care providers. Contact HR&P for additional COVID-19 resources.

Source: Centers for Disease Control and Prevention


This Bulletin is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. Design ©2020 Zywave, Inc. All rights reserved.

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