Introduction

The COVID-19 pandemic has exposed deep vulnerabilities in our nation’s public health infrastructure. We’ve lost lives, intensified inequities and eroded years of progress across our economy. Getting back to our lives—back to seeing our loved ones, back to school and back to business—requires that we turn the tide against COVID-19 and create a stronger, healthier future for all of us. Vaccines, highly effective and safe, offer hope and protection that can help our country and our economy rebuild and recover.

We’re on our way, but significant challenges remain, including the emergence of a highly transmissible Delta variant that’s driving a new wave of infections across the country. Public health officials warn that we must encourage many more Americans to get vaccinated, including more than 80 million people in the United States who are currently eligible for vaccines but remain unvaccinated and at real risk.

On November 4, the federal Occupational Safety and Health Administration (OSHA) issued its anticipated COVID-19 rules for roughly 116,000 private businesses with 100 or more employees firm or company-wide, a sweeping new measure that's designed to protect 84 million workers on the job. Those rules—currently on hold pending a legal challenge in federal court—require vaccination or weekly testing for COVID-19 by January 4, 2022, with exceptions only for people with a medical disability or religious accommodation. Beginning December 6, 2021, employers will also be required to offer workers paid time off for vaccination and recovery from possible side effects, as well as require unvaccinated workers to wear face coverings at the workplace.

Now that the question of whether to require vaccinations has been settled, employers face a long list of questions about how to do it.

Fortunately, there are now numerous examples of companies that have implemented vaccine mandates successfully; the roadmap is already in place. Employers that have not already begun laying the groundwork for vaccine requirements will need to act swiftly. Employee communication and engagement strategies, stakeholder feedback coupled with change management can do much to maintain morale and avert staff losses.

This guide is designed to help you get started.

Summary of Recommendations

A fully vaccinated workforce creates the safest possible workplace environment for employees and customers. It may also be the most equitable policy, especially if the alternative is regular testing, paid for by your workers. If a vaccination requirement is not an option for your business, we recommend these steps:

  • Routine Testing: Require all workers and regular visitors (not retail customers) to be routinely screened with a rapid test, at least weekly. Repeated negative tests provide a high degree of certainty that the individual is not infectious. Beginning January 4, 2022, testing at least weekly is required for employers of 100 or more workers who do not have a COVID-19 vaccination requirement.
  • Proof of Vaccination: Allow anyone who provides proof of full vaccination (accounting for the appropriate time period after the final vaccine) to bypass the routine testing requirement.
  • Support Workers: Employers are encouraged to provide paid time off for vaccinations and recovery from possible side effects—which is required for employers of 100 or more workers beginning December 6, 2021. Businesses should extend this support to  working parents who choose to vaccinate eligible children, too. Consider organizing on-site vaccination clinics for workers and families, or offering transportation support, childcare or incentives to improve access to vaccines.
  • Mask Use: Require masks for all employees and customers, regardless of vaccination status, in areas with substantial or high transmission. As more people get vaccinated in these areas, transmission rates  are expected to drop. Beginning December 6, 2021, employers of 100 or more workers must require unvaccinated workers to wear masks.

 

Employers are encouraged to: 

 

  1. Create a clear COVID-19 vaccination policy for employees, part-time workers, temporary workers and contractors that requires or encourages vaccination, reduces barriers and makes it easy for them to get vaccinated. Your policy should be aligned with your company’s values and reflect the unique needs, concerns and questions of diverse communities. 
  1. Share facts about the safety and benefits of COVID-19 vaccines. Invite trusted experts to answer questions during paid working hours.
  1. Create a safe, supportive workplace culture where all workers feel supported. Understand that no community shares all of the same beliefs, perceptions and concerns. Every individual is unique, and every employee deserves to have their questions answered before making a decision about vaccines. Getting vaccinated is an individual choice that you should respect — even if it means an employee cannot continue working for you.
  1. Strengthen vaccination efforts in your community by engaging with public health departments, nonprofit organizations and others involved in the vaccine response.

 

As you consider how to implement your company’s COVID-19 vaccination policy and workplace safety protocols, you should be guided by trust and empathy, meaningful input from workers representing communities disproportionately impacted by COVID-19, the specific values of your company, and needs of your community.

Disclaimer

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A fully vaccinated workforce creates the safest possible workplace environment for employees and customers. If a vaccination requirement is not an option for your business, we recommend these steps:

  • Routine Testing: Require all workers and regular visitors (not retail customers) to be routinely screened with a rapid test, at least weekly. Repeated negative tests provide a high degree of certainty that the individual is not infectious.
  • Proof of Vaccination: Allow anyone who provides proof of full vaccination (accounting for the appropriate time period after the final vaccine) to bypass the routine testing requirement.
  • Support Workers: Employers are encouraged to provide paid time off for vaccinations and recovery from possible side effects — which the Department of Labor will now require for employers of 100+ workers. Businesses should extend this support to  working parents who choose to vaccinate eligible children, too. Consider organizing on-site vaccination clinics for workers and families, or offering transportation support, childcare or incentives to improve access to vaccines.
  • Mask Use: Require masks for all employees and customers, regardless of vaccination status, in areas with substantial or high transmission. As more people get vaccinated in these areas, transmission rates  are expected to drop.

 

Employers are encouraged to: 

 

  1. Create a clear COVID-19 vaccination policy for employees, part-time workers, temporary workers and contractors that requires or encourages vaccination, reduces barriers and makes it easy for them to get vaccinated. Your policy should be aligned with your company’s values and reflect the unique needs, concerns and questions of diverse communities. 
  1. Share facts about the safety and benefits of COVID-19 vaccines.
  1. Create a safe, supportive workplace culture where all workers feel supported. Understand that no community shares all of the same beliefs, perceptions and concerns. Every individual is unique, and every employee deserves to have their questions answered before making a decision about vaccines. Getting vaccinated is an individual choice that you should respect — even if it means an employee cannot continue working for you.
  1. Strengthen vaccination efforts in your community by engaging with public health departments, nonprofit organizations and others involved in the vaccine response.

 

As you consider how to implement your company’s COVID-19 vaccination policy and workplace safety protocols, you should be guided by trust and empathy, meaningful input from workers representing communities disproportionately impacted by COVID-19, the specific values of your company, and needs of your community.

Strengthen Your COVID-19 Vaccination Policy and Workplace Safety Protocol

All employers are encouraged to develop a COVID-19 vaccination policy and workplace safety protocol that reflects a careful review of the latest public health, legal and safety considerations. As employers weigh these options, they should prioritize the health and safety of workers and customers and consider local community vaccination rates and guidance from local public health officials. They should also plan to regularly evaluate and update policies and protocols as the pandemic and federal, state and local guidance evolve.

 

A fully vaccinated workforce creates the safest possible workplace environment for employees and customers. The CDC recommends people get vaccinated even if they have already had COVID-19, as evidence is emerging that being fully vaccinated provides greater protection. All people in the United States ages 5 and older are now eligible to receive COVID-19 vaccines, and the FDA has fully approved the Pfizer vaccine for those 16 and over.. Vaccines are free and widely available at more than 80,000 locations across the country, including over 40,000 retail pharmacies. Ninety percent of Americans live within five miles of a vaccine site. 

 

Against the backdrop of a still surging Delta variant, employers should develop a plan to remove barriers to vaccination and make it easier for employees and workers to get vaccinated at their earliest opportunity. Existing plans and policies may need to be updated to reflect the federal requirements for companies of 100 or more workers and new recommendations that employers offer paid time off and other support to working parents who want to vaccinate eligible children against COVID-19.  

 

Step 1: Designate a coordinator or task force.

 

Building your company’s COVID-19 Vaccination Policy and Workplace Safety Protocol will require navigating technical, logistical, organizational and communications challenges. Identify a leader within your company who’s adept at responding to employee, worker and stakeholder questions, and is well-positioned to coordinate with management, human resources, employee resource groups, workers and labor representatives, as appropriate. Leading your company’s COVID-19 vaccine planning is a complex and time-consuming assignment, so be sure to empower a leader who has the authority, trust, empathy, communication skills and capacity to serve in this role. 

 

For larger companies, you may want to establish a COVID-19 vaccine task force with representation from each of the key departments. Input from a racially and ethnically diverse cross section of your company can help ensure you understand specific needs and questions within communities that have been hit hardest by the virus.  

 

What should they do?

 

  • Review the latest public health, legal and safety considerations that can inform the development of your company’s plan;
  • Coordinate among different internal departments (e.g. legal, health, employee resource groups) and external stakeholders (e.g. unions, public health departments, health insurance providers);
  • Identify and minimize any barriers to vaccination, such as time off, daycare or transportation;
  • Gather employee and worker feedback in real time and listen to questions and concerns;
  • Engage employees and workers from disproportionately impacted communities, including via employee resource groups and other networks that represent workers at highest risk;
  • Stay abreast of employee vaccination trends and concerns to adapt the plan as needed;
  • Oversee internal and external vaccination communications.
  • Identify opportunities for your company to partner with state and local public health agencies and community-based organizations to support vaccine distribution in your area.
  • Establish measurements of your policy’s effectiveness, including changes in vaccination rates, exemptions requested and received, administrative costs, employee satisfaction, and personnel turnover


Step 2: Engage workforce populations that may have unique questions, concerns or access needs.
 

As you develop or refine your plan, make sure you proactively engage leaders of your company’s employee resource or affinity groups and other employee populations that may have unique questions, concerns or access needs. This isn’t about convincing workers to trust the vaccine; it’s about understanding their perspectives and concerns, and working together to identify solutions. Because some demographic groups face barriers to vaccines, those employees may be negatively and disproportionately impacted by a vaccination requirement. Below are strategies you may consider:

  • Black, Hispanic, Asian-American, American Indian and Alaska Native communities have been disproportionately impacted by COVID-19, and have experienced higher rates of hospitalization, severe illness and death. If you’re not a member of these population groups, start by learning more about why these inequities exist and how they might contribute to additional questions about vaccines. You can support employees and workers by acknowledging the deep historical traumas and structural inequalities that lead to poorer health outcomes and contribute to greater mistrust.
  • Invite leaders from your company’s employee resource groups to participate in your company’s COVID-19 Vaccine task force and meaningfully contribute to developing your company’s vaccine plan.
  • Organize listening sessions with workers representing communities disproportionately impacted by COVID-19 to make sure all interests are heard, and develop plans that meet the communities’ needs 
  • Reach out to local community organizations, healthcare provider networks, faith leaders or other trusted influencers within diverse populations to seek their counsel and feedback on your company’s plan. 

 

Step 3: Draft your company policy.

On November 4, 2021, the the Occupational Safety and Health Administration (OSHA) issued new rules that obligate all employers with more than 100 workers to require vaccination or weekly testing for COVID-19. A fully vaccinated workforce creates the safest possible workplace environment for employees and customers. Hundreds of major companies have announced policies to require vaccinations for all or part of their workforce, adding to the millions of federal workers and contractors now required to show proof of vaccination. If a vaccination requirement is not an option for your business, we recommend these steps:

 

  • Routine Testing: Require all workers and regular visitors (not retail customers) to be routinely screened with a rapid test, at least weekly. Repeated negative tests provide a high degree of certainty that the individual is not infectious. Beginning January 4, 2022, testing at least weekly is required for employers of 100 or more workers who do not have a COVID-19 vaccination requirement.
  • Proof of Vaccination: Allow anyone who provides proof of full vaccination (accounting for the appropriate time period after the final vaccine) to bypass the routine testing requirement.
  • Support Workers: Employers are encouraged to provide paid time off for vaccinations and recovery from possible side effects — which is required for employers of 100 or more workers beginning December 6, 2021. Businesses should extend this support to working parents who choose to vaccinate eligible children, too. Consider organizing on-site vaccination clinics for workers and families, or offering transportation support, childcare or incentives to improve access to vaccines.
  • Mask Use: Require masks for all employees and customers, regardless of vaccination status, in areas with substantial or high transmission. Beginning December 6, 2021, employers of 100 or more workers must require unvaccinated workers to wear masks.

You may customize your workplace policy using our Sample COVID-19 Vaccination Requirement Policy as a guide. It is updated to reflect OSHA’s COVID-19 rules for employers of 100 or more workers.

 

Additionally, our Guides for Responding to Requests for Medical Exemptions and Religious Exemptions provide step-by-step recommendations for handling these requests and providing reasonable accommodations. And our Sample Request Forms for Medical Exemptions and Religious Exemptions will help your company assess these requests in a consistent and orderly way.

 

We’ve created an interactive Decision Tool with the latest health, legal and safety considerations to help guide your planning and decision-making. Our recommendations are based on public health guidance from the U.S. Centers for Disease Control and Prevention (CDC), safety guidance offered by the Occupational Safety and Health Administration (OSHA), legal considerations established by the Equal Employment Opportunity Commission (EEOC) and additional feedback from COVID Collaborative and the National Safety Council. 

 

Here are some of the key questions your company’s policy should address:

 

Vaccine Requirements

 

Paid Time Off & Incentives

 

Masking & Other Safety Protocols

 

Prioritize Equity 

Equity should be top of mind as you develop your policy. Apply an equity and access “lens” to ask yourself whether your policy risks harming workers from populations already disproportionately impacted by the pandemic. Here are some steps your company can take:

  • Consider applying a single policy across all sectors of your workplace 

Having different requirements for different sectors of your workforce — for example, requiring vaccines for employees in the office, but not for those in customer-facing roles — risks creating a tiered system of safety. Especially if workers from disproportionately affected communities predominate in certain roles, employers should strive for a consistent policy that prioritizes everyone’s health and safety. Make policies and enforcement transparent, consistent and equitable across your workforce.

  • Offer positive incentives before taking punitive actions.

Well-intended “nudges,” such as healthcare plan surcharges on unvaccinated workers, might make health insurance unaffordable for lower-income employees, hourly workers and communities of color. As an alternative, ask workers from hard-hit communities what incentives would encourage them to get vaccinated and offer that instead. 

  • Be thoughtful about your messengers and messages.

Cultivate trusted messengers who reflect a diversity of communities and can speak to the unique concerns of affected groups. (This tip sheet can help you source a trusted doctor or community leader). It’s also important to make sure you have messaging and resources in Spanish or other native languages spoken by your workforce. In written communications and in conversation, build trust, express empathy and listen for what’s holding people back then help them find their own reason to get vaccinated. 

  • Share stories from like-minded employees who’ve gotten vaccinated.

Invite employees from underrepresented groups who have been vaccinated to share their vaccination experience, as well as stories of how the pandemic may have impacted them and their families. Studies show that people are 40% more likely to get vaccinated if they know a friend or family member who was vaccinated, too, and reassuring stories from peers are almost as important as getting the facts.

  • Provide ample time for employees to get vaccinated, including time that may be needed to learn more about vaccines or get questions answered from a doctor or other trusted source.

 

Paid time off to get vaccinated and recover from possible side effects — for workers themselves and eligible family members — is one of the most significant barriers to vaccination. Even beyond that, employees may need time or assistance to navigate online portals to book appointments, to arrange travel to/from their vaccine appointment, and to plan for potential side effects to the vaccine. Some workers may need time to learn more about vaccines, speak with a doctor or other trusted source or consider how they’ll respond to workplace requirements before ultimately getting their shot.  And finally, make sure to extend paid time off, incentives and other benefits across your entire workforce, including hourly, seasonal, and part-time workers.

 

Employers should also consult their legal counsel and review state and local laws before making any decisions about workplace policies related to the pandemic. 

 

Additional Ways to Support Workers

Research has shown additional ways employers can support or incentivize workers to get vaccinated.

  • Cover out-of-pocket expenses associated with vaccination. This could include offering an Uber or Lyft gift card for transportation, a small stipend for lunch or reimbursement for child care.  
  • Extend benefits and support to your entire workforce, including temporary, part-time or contract workers.
  • Help identify where workers can get vaccinated. Search vaccines.gov, text your ZIP code to 438829, or call 1-800-232-0233 to find locations near you. 
  • Offer internet access or language support services to help employees and workers schedule appointments.
  • Some small businesses may be able to partner with a local public health department or other providers to offer on-site vaccinations to employees and workers, even during late shifts, and to their eligible family members.
  • Consider providing small prizes, rewards or other modest financial incentives (i.e., gift cards, coupons, tokens, etc.) to employees and customers workers who get vaccinated.

 

Remind employees that vaccines are free and available to everyone in the United States ages 12 and older, regardless of immigration status. You don’t need health insurance to get a COVID-19 vaccine.

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Educate and Encourage Your Workforce

There are still 65 million Americans who are eligible to get vaccinated but remain unvaccinated and at real risk. As an employer, the most important thing you can do is communicate with your employees, workers and customers about the benefits and safety of COVID-19 vaccines and encourage them to get vaccinated. Your outreach can also help counter misinformation about vaccines.

Vaccines save lives. They also require trust, transparency and accountability. The factors that influence a person’s decision to get vaccinated are nuanced and affected by how they see and experience the world. Science and facts aren’t the only predictors of human behavior. People make vaccine decisions based on social norms, their perceptions of how others will view their decision, feedback from people they trust, their perceptions of risk, the consistency of messages and the convenience of getting vaccinated.

It all starts with trust.

Fortunately, new research suggests that Americans trust their employers more than they trust government leaders, community leaders and even religious leaders. That’s why it’s important you share trusted information from the CDC, FDA and other public health experts, as well as perspectives and encouragement from trusted community leaders to help your employees, workers, customers and other stakeholders make the best decisions for themselves and their families. And, you can listen and respond to their questions and needs, as well as dispel misinformation about company policies or vaccination issues that may arise. 

All vaccine requirements, whether mandated by the federal government or initiated independently, need thoughtful planning and communication. To help you get started, we offer general communications guidance and a range of free tools and resources to help employers communicate about COVID-19 vaccine requirements to workers, customers and the media. There’s no one-size-fits-all approach, so you should be prepared to customize outreach for groups with unique needs and questions. 

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Support Vaccine Distribution in Your Community

Delivering and administering hundreds of millions of COVID-19 vaccinations represents one the greatest communications, logistical and public health challenges in our country’s history. The private sector has unique expertise and resources that can help accelerate the vaccine response, save lives and contribute to a faster recovery. 

 

There are many ways your company might support local public health officials and strengthen vaccine distribution in your community. 

  • Lead by example. As a trusted leader in your community, you can encourage other businesses to share facts about the safety and benefits of vaccines; offer paid time off to workers for vaccine appointments and recovery, including to attend vaccine appointments with eligible children; and, align workplace safety protocols with the latest public health guidance.
  • Encourage your local chamber of commerce or Rotary club to host an educational conversation on the role of businesses in the vaccine response, and volunteer to share what you’ve learned.
  • Encourage your customers to get vaccinated by offering special coupons, discounts or other incentives. (We’ve compiled great examples of companies offering customer incentives.) 
  • Share vaccine facts on your product packaging or at your place of business.
  • Donate advertising space or airtime to your local public health department or to community organizations that are educating the public about the vaccines. (Or if they don’t have a local campaign, sponsor them to create one or donate your ad agency’s time to help.)
  • Engage with your local public health department to help address other needs, including transportation, childcare, language support or other services that may help improve access and remove barriers to vaccination in your community.

If you’d like to donate space, staff, or supplies to aid local vaccination efforts, your local public health department is the place to start. For those who are not already in contact with their local public health department, this outreach can serve as an introduction that helps to build a longer-term partnership focused on your company’s health, wellness and preparedness goals. 

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Our Tools and Resources

We’ve prepared tools, templates and communications resources to help you engage employees, workers, customers and other stakeholders:

Health Action Alliance’s digital resource hub contains our full suite of tools, resources, case studies, training opportunities and information about upcoming events. You can also SIGN UP to receive our latest resources, updates and event invitations!

Additional Resources

CDC Resources

 

Health Equity

 

Data and Tracking

 

Public Opinion

 

Mental Health

 

Media & Entertainment

 

Communications

 

Employer Resources

Small Business Resources


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About HAA

The Health Action Alliance unlocks the power of business to create a healthier workforce and thriving communities.


Guided by the nation’s most trusted sources on public health, the companies in our network:


  • Accelerate the response to the most pressing health challenges
  • Strengthen resilience by prioritizing the health of their communities
  • Emphasize equity to advance access to health for all
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