Vaccine Mandates: Steps and Tools to Assist with Compliance

Over the last few weeks, several COVID-19 vaccine-related policy proposals affecting various employee types and employer configurations were released at the federal level. These proposals would require some employers to verify vaccination status and/or monitor weekly testing compliance for employees who opt out of vaccines or have a qualified exemption.

Details about these proposals, which could impact an estimated 80 million employees (including those working in schools), are still pending. Below, we summarize the contents and status of each proposal underway, as well as steps that employers can take to ensure compliance with them.

Employers with 100+ Employees

  • September 2021: Biden released his “Path Out of the Pandemic” announcement, stating that the Department of Labor’s Occupational Safety and Health Administration (OSHA) is developing a rule that will require all employers with 100 or more employees to either:
    • Ensure that their workforce is fully vaccinated, or
    • Require unvaccinated employees to produce a negative test on at least a weekly basis before coming to work.
  • October 2021: The OSHA rule was sent to the White House Office of Information and Regulatory Affairs on October 12th. The regulatory review will likely conclude soon, as the rule has been deemed an emergency standard. It is unknown what the timeline for compliance will be for these forthcoming standards.

Federal Employees & Contractors

  • September 2021: The administration releases the Executive Order on Requiring Coronavirus Disease 2019 Vaccination for Federal Employees, which requires federal agencies to implement—to the extent consistent with applicable law—a program to mandating COVID-19 vaccination for all of its federal employees.
    • This mandate applies to teachers and staff at Head Start early education programs, as well as individuals working in other federally funded educational settings (such as those on military bases).
  • October 2021: Ahead of the November 22 deadline, the Office of Management and Budget (OMB) released new guidance for federal workers to be fully vaccinated, including strict conditions related to exemptions from the vaccine mandate:
    • Employees must get the first shot within two weeks of an exemption request being denied, or the resolution of a medical condition.
    • Federal agencies may deny medical or religious exemptions if they determine that no other safety protocol is adequate for certain workers.
    • Neither a past COVID-19 infection nor an antibody test are a substitution for vaccination.

Public Consulting Group (PCG) has worked with states and schools throughout the pandemic to conduct contact tracing, COVID-19 testing, and case investigations. To address the emerging need for vaccine mandate compliance for schools, businesses, and other organizations, PCG developed a mobile application and web-based system to help organizations track and report on vaccination status and weekly test results. The application has an easy-to-use interface for employees or testing partners to input information, and the web portal enables administrative users to generate reporting for program oversight.

Additionally, PCG subject matter experts compiled a checklist for Health Policy News readers that includes steps and tools to manage the vaccine mandates. Click the thumbnail on the right to view it.

To learn more about how PCG subject matter experts can assist with vaccine mandate compliance, please email us at

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