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HR professionals at companies with 100 or more employees should get ready for the vaccine mandate.

While it will likely be challenged, employers should still consider what they will be doing to comply.

While all the details of the mandate are still unknown, employers will likely need to give employees time off to get vaccinated, and test those who are not vaccinated.

Where we are, as of October 22

On September 9, President Biden announced that private employers with at least 100 employees will need to ensure that employees are either vaccinated or tested for COVID-19 weekly before coming to work. The details were to be announced in an emergency temporary standard from the Occupational Safety and Health Administration (OSHA).

Late in the day on October 12, OSHA reportedly submitted a proposed ETS to the Office of Management and Budget (OMB). OMB reviews usually take a week or two, so the ETS could be released any day now.

What can you do now to get ready?

  • Get ready to deal with data. There will likely be a lot of information to track. Determine if your company’s human resource information system (HRIS) can be used to upload employee vaccination status. If you don’t have an HRIS, research other solutions (yeah, there’s an app for that), or create your own system. If you create a spreadsheet that will contain records of employee vaccination dates remember that it must be stored confidentially, similar to any other employee medical information.
  • Establish a relationship with a testing site (or two). Employees who ask for and receive an accommodation under a religious or medical exemption will require weekly testing. Talk with a few local testing facilities to get a handle on which ones can take care of your testing needs most efficiently. This may allow employees to test during working hours and have results easily sent to your HR department.
  • Explore the possibility of having an onsite vaccination clinic. This is a way to make complying with the mandate as easy as possible for employees.
  • Ramp up communication. Remind employees that this mandate may be coming, and you’ll share the details when you know them. Be positive and remind employees that getting vaccinated will benefit them individually and will also benefit the organization. Once the mandate is out, explain the details clearly.