Although the federal vaccine mandate overseen by OSHA was struck down by the Supreme Court on January 13, a number of FORTUNE 500 businesses still plan to enforce vaccine requirements for their workforces, even though they’re no longer legally bound to do so.
If you believe that vaccine requirements are appropriate for your business, it’s important to put a system in place to track your employees’ vaccination status, as well as record COVID test results and other data.
Assess the situation
To start, I recommend collecting data about your current staff by asking the following questions:
- Are you fully vaccinated?
- If you are partially vaccinated, when do you plan to be fully vaccinated?
- Can you produce a card proving your vaccination status?
- If you are not vaccinated, what is your reason? Is there a specific objection you have to getting vaccinated?
Federal law requires that you accommodate valid medical and religious exemptions if an employee requests to be exempted from the vaccination requirement. For this reason, your policies should explain how employees can request exemptions on the basis of medical or religious reasons.
For more details about verification of vaccination status, Fisher Phillips has prepared useful information on what employers need to know.
Implement a system for test results
Under the ‘vaccine-or-test’ requirement proposed by the OSHA mandate, employees who are not vaccinated were required to be tested weekly. If you follow this rule, you will need to create a system for collecting test results. As an employer, you might consider bringing on-site testing to the office each week. Otherwise, employees will need to bring in testing results from a facility. At-home tests aren’t recommended because the employee could have someone else take it on their behalf. In addition, as we’ve seen in the news lately, at-home tests may be in short supply or difficult to find.
For templates and checklists to follow regarding recording test results, visit the OSHA site that contains information about employee tracking.