- Employee Count & Coverage
The 100-employee count should be done at the corporate-wide level. If your company is based in multiple cities or states, all employees at all locations should be counted.
Employees who work exclusively from home should be included in the total employee count. However, only employees who work at an office will be mandated to be vaccinated or have weekly testing. This logic also applies to employees who work exclusively outdoors.
- Policy
Employers need to create an internal policy that mandates vaccination for everyone or a policy that says you must be vaccinated or tested weekly. Employers must collect vaccination proof, verify who is vaccinated, and keep an updated roster of everyone’s status.
- Paid Time Off
Employers must provide up to 4 hours of Paid Time Off (PTO) per vaccine dose for employees. The time off needs to be “new time” and not existing or accrued PTO.
In addition, employers will need to give up to 2 days to recover from the doses and any potential symptoms. Those 2 days can be charged against existing PTO or can be used with allotted sick days.
- Vaccination & Testing
Fully vaccinated individuals are categorized as having received all doses from their respective provider and 14 days have passed since their last dose. If employees are still waiting to be vaccinated, they must get the last dose before the federal compliance date, January 4, 2022, in order to not be subject to the weekly testing regulations.
Medical disabilities and religious exemptions will apply for employees who do not wish or are advised against being vaccinated.
Unvaccinated employees will be subject to COVID-19 tests every 7 days and need to wear masks any time they are indoors (unless in a room or office by themselves). Employees who test positive for COVID-19 must be excused from the workplace and follow current CDC guidelines. In addition to an employee being excused from the workplace for testing positive, the regulations state that you cannot make the employee test again for 90 days.
- Timing
The OSHA ruling was immediately in effect upon publication.
By December 6, 2021, employers must have an internal policy in place and communicate the policy to employees, determine each employee’s vaccination status, and implement a face mask mandate for those not vaccinated.
By January 4, 2022, employers must ensure that unvaccinated employees undergo weekly testing.
Although there is ongoing uncertainly around the OSHA mandate, covered employers are still encouraged to move forward with an internal solution and policy.
The ThrivePass Vaccine Verification Solution has you and your workforce covered for all regulatory requirements. Learn more.
