Managing a Partially Vaccinated Workforce: Tips for Employers

The Centers for Disease Control and Prevention (CDC) recently released new guidance for fully vaccinated individuals. The new guidance states that fully vaccinated people can resume normal activities without wearing masks or physical distancing, except where required by federal, state, local, tribal, or territorial laws, rules, and regulations, including local business and workplace guidance.

You may be wondering: what does this new guidance mean for employers with partially vaccinated workforces? Here are some actions to consider:

  • Read up on the CDC’s new guidance. Some settings must still require masks and social distancing regardless of vaccination status. Healthcare, congregate living, and public transportation settings are among them.
  • Consider taking a risk-based approach to ensure the safety of all employees. While this new guidance means that your fully vaccinated employees will be able to safely remove their masks and discontinue social distancing, it also presents some challenges in managing the safety of a partially vaccinated workforce.
    • Employers should determine a COVID-19 safety protocol based on their specific work environment.
      • For example, if your workforce interacts with the public regularly and a large portion of workers are unvaccinated, you may consider requiring masks and social distancing for employees and patrons. If the majority of your staff is vaccinated and your business is closed to the public, you may consider a more relaxed COVID-19 safety protocol. Visit the National Safety Council for more tips.
  • Encourage your employees to get vaccinated. The COVID-19 vaccines offer the clearest path back to normal. Health Action Alliance has put together a roadmap employers can utilize to strengthen vaccination efforts:
  • Before instituting any vaccination policy, double-check state and federal laws.  
    • The U.S. Equal Employment Opportunity Commission (EEOC) updated its materials on May 28 to reflect updated guidance from the CDC for fully vaccinated individuals. The new guidance from the EEOC confirms that an employer may require all of its employees physically entering the workplace to be vaccinated against COVID-19. However, employers must comply with their reasonable accommodation obligations under the ADA and Title VII for employees seeking exemptions from a mandatory vaccination program. The EEOC suggests that reasonable accommodations could include masking, working at a social distance from others, working modified shifts, getting periodic testing for COVID-19, teleworking, or reassigning the employee. 
    • The EEOC’s guidance only covers federal EEO laws and some state and local laws may place greater restrictions on an employer’s ability to mandate vaccinations in the workplace or provide vaccine incentives. Missouri has two House Bills on this topic currently pending. Any employer considering vaccine mandates or incentives should consult legal counsel before implementing such policies. 
  • Stay up-to-date on federal, state, and local guidance. Businesses should anticipate updates from OSHA based on this new guidance.

There are many factors to consider as you strive to protect your workforce. As vaccination efforts continue, make sure to stay up-to-date on guidance from the CDC as well as state and federal laws and guidance.

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