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Giving Employers Their Best Shot at Effective COVID-19 Vaccine Policies

March 10, 2021

Woman receiving vaccine

As we head into the second year of widespread shutdowns caused by the COVID-19 pandemic, one essential step in getting employees safely back to the workplace will be vaccination. Though COVID-19 vaccinations bring a sense of hope for returning to some level of business normalcy, a looming question remains for many employers: how can we implement a vaccine policy that prioritizes employee health and safety while protecting the business against any potential risks?

According to a recent Paychex survey of 300 principals of U.S. companies with 2 to 500 employees, advice, paid time off, positive reinforcement and financial support are motivating tools planned by employers to encourage employees to get vaccinated: 25% of respondents will share educational resources about the vaccine, 24% will provide paid leave to get vaccinated during work hours, and 19% will celebrate or acknowledge employees who get the vaccine.

However, more than half (51%) of employers say they will not provide an incentive to get the shot, saying “It’s not my place” and one in four businesses say concerns about legal liability and vaccine safety will keep them from incenting employees.

With all these options on the table, it’s important that employers begin to map out a plan for developing a vaccination policy. While COVID-19 vaccines are being distributed in a phased approach and it’s unlikely that the general population will have access to a COVID-19 vaccine until much later in 2021, business leaders should start planning now as many of their employees may be eligible and there is a lot to consider.

Not sure where to start? Here are some questions to get the ball rolling.

  • What is the latest guidance from the local health department? Local infection rates may help guide a decision on whether vaccinations will be required to return to the workplace.
  • What reasonable accommodations would preclude an employee from receiving a vaccine should a company decide to mandate the COVID-19 vaccine? Under the Americans with Disabilities Act (ADA) an employee could have a medical condition, for example pregnancy, that would be considered a disability, or covered condition under state or local laws, that may impact their ability to receive the COVID-19 vaccine. In other cases, an employee may have a sincerely held religious belief that prevents them from being vaccinated.
  • Are there rules or limitations around incentives? Depending on the type of incentive and the type of information that employers require from their employees, some incentive programs may fall under the rules governing employer wellness programs. Therefore, all businesses should consult with legal counsel before implementing any incentive program to help ensure compliance with applicable federal, state, and local laws.
  • How will the policy be communicated? After consulting with their legal counsel, employers who plan to mandate or incentivize COVID-19 vaccinations for some or all of their employees should effectively communicate their vaccine policy to employees and plans related to reasonable accommodations. Communications around the vaccine should be clear, consistent, and proactive, so that employees feel informed and taken care of during this time of uncertainty. Companies that span across multiple states may also need to develop localized vaccine policies depending on local and state laws.

There is a light at the end of the pandemic tunnel for employers, but there is still no shortage of complexities. Employers can access the Paychex Coronavirus (COVID-19) Help Center for more resources, including answers to COVID-19 vaccine FAQs, to help manage the various impacts of COVID-19 on their business.

Mike Trabold

Mike Trabold

Mike Trabold is the director of compliance risk management for Paychex. In his role, Trabold directs the compliance and regulatory activities of the company, which serves 680,000 clients, and his team is responsible for compliance programs for all products and subsidiaries, as well as managing the company's relationships with various federal, state, and local regulators and tax agencies. Trabold is on the Board of Directors of the National Payroll Reporting Consortium (NPRC), a member of the American Payroll Association's (APA) Government Affairs Task Force, and a member of the APA's Retirement Subcommittee. Connect with Mike on LinkedIn.

Director of Compliance Risk