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  • Thomas Spreitzer

Things to Know About Vaccine Mandate

Updated: Sep 29, 2021

The Biden Administration recently issued an executive order requiring the vaccination of the unvaccinated, impacting businesses, large and small, across the U.S. The Department of Labor’s Occupational Safety and Health Administration (OSHA) is developing a rule which will require:


  • All employers with 100 or more employees ensure that all employees are fully vaccinated or produce a negative COVID-19 test result weekly.

  • Certain government contractors comply with the mandate. Employees who work on or in connection with certain government contracts may be required to be vaccinated, regardless of whether they work on a federal site.

  • COVID-19 vaccination for workers in most health care settings that receive Medicare or Medicaid reimbursement as a condition of Medicare/Medicaid reimbursement. The Centers for Medicare & Medicaid Services (CMS) is leading this requirement.

What Employers Need to Know

Employers who are affected must determine how to manage legal issues and operational challenges of required vaccination and testing.

  • Workplace testing

  • Vaccination tracking and management

  • Medical records and HIPAA compliance

  • Religion, disability, and pregnancy exemptions

  • Union concerns

  • Privacy issues

Since there are many missing pieces to the puzzle, we expect clarification from the federal government in the weeks to come. In the meantime, preparation for the worst-case scenario is always the best path.

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