An Employer’s Role in Supporting COVID-19 Vaccine Distribution

An Employer’s Role in Supporting COVID-19 Vaccine Distribution


As the COVID-19 vaccine becomes more widely available, you’re probably thinking about the risks and potential benefits to your employees, your organization and the economy as a whole. Here are five things to consider as you think about how to position yourself:

Should you require or encourage employees to get the vaccine?

Your answer probably depends on the extent to which your employees have close exposure to clients or the public. If you believe the risk is high, you may have grounds to require the vaccine. But be sure to clearly document your rationale and provide accommodations for those who don’t want to take it based on health concerns, religious beliefs or other reasons. Also, keep in mind potential barriers to vaccine availability. We recommend consulting the EEOC’s Guidance on this topic.

You certainly have a lot of room to encourage employees to get the vaccine, as you do currently with the flu vaccine and other preventive health measures.

Will employees be charged for the vaccine?

Fully insured plans are covering the vaccine at 100% with no deductible, and most self-insured plans also cover it. But employees who aren’t on the organization’s health plan may have to pay for the vaccine. At this point, there isn’t a lot of guidance on the best way for employers to reimburse employees for that cost (if they want to), but it’s an issue we’re tracking closely.

Should you educate employees about the vaccine?

Many employees are looking to their employers for guidance on this topic. Whether you want to encourage it or not, you may want to at least inform them about its availability and how your medical plans cover it. You also may want to address common questions about the benefits and safety of the vaccine. The CDC’s Information tends to be reliable and objective.

What additional information should you provide?

Employees need to continue taking precautions, even as they’re vaccinated. Part of your instruction on workplace safety should include encouragement to continue following the CDC Guidelines – before and after they’re vaccinated. This includes:

  • Wash your hands often
  • Avoid close contact
  • Cover your mouth and nose with a mask when around others
  • Avoid touching your face (particularly the mouth and nose) whenever possible
  • Cover coughs and sneezes
  • Regularly clean and disinfect surfaces
  • Monitor your health daily
  • Self-quarantine after a known exposure
How can you integrate this phase – and the next – into your ongoing business planning?

If you haven’t already done so, you may want to establish a COVID-19 committee to serve as the organizational experts in managing workplace policies and issues surrounding the vaccine, return to work, etc. Consider including representation from multiple areas in the organization, such as HR, communications, legal and safety. I strongly suggest including a few frontline staff members to represent your overall population.

The National Safety Council has some great resources to help you plan, as well.

This issue is changing daily, and we’ll continue working to keep you informed. Meanwhile, feel free to contact me if you have additional questions.

By Julie Athey, J.D., Director of Compliance, The Miller Group

See also:

COVID-Inspired FSA Provisions Offer Increased Flexibility For Employees
COBRA: Common Mistakes, Oversights And COVID Effects
Consider Reporting COVID-Related Losses

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