How to navigate the new COVID-19 employer requirements
Employers should be ready for more complex record-keeping.
Employers are on notice after the Biden administration announced that companies with 100 or more workers will be required to track employees who have received the COVID-19 vaccination and conduct weekly testing for those who are not immunized. For small to medium-sized companies, especially, the directive could seem daunting. I know many employers are still rebounding from 2020 and have limited resources available to implement and manage a new mandate, but the costs for non-compliance are steep, with fines of up to $14,000 per violation possible.
Although the details of the government requirements are not yet known, companies can begin basic planning around record-keeping, payment allocation, and reporting immediately to stay ahead of the curve and keep their employees informed.
Related: Businesses question logistics, cost of Biden vaccine plan
One asset that all employers have is the ability to use technology to track immunizations and plan for testing for those employees who are not able to receive the vaccine. Additionally, consider how immunization records will be documented. Many employees will have electronic access to their immunization records either through the state or from the place where they received the immunizations. Walmart, for example, allows pharmacy customers to receive electronic copies of their vaccinations using a QR code. Many pharmacies and providers also send vaccination records directly to an employee’s mobile phone. Employers should work with employees for submissions of their vaccine records but also make sure that the systems they have in place meet compliance and security guidelines.
Employers should be ready for more complex record-keeping, using a lane-assigned approach. For example, you will need to know the number of employees who are fully vaccinated (two doses for Pfizer and Moderna; one dose for Johnson & Johnson) as well as those needing their second dose for compliance. Tracking employees who either cannot receive the vaccinations or have yet to be inoculated will be expected, too, so employers should decide how these records will be updated as vaccination status changes. Finally, this lane-based system should have room to add in boosters, in the event they become a requirement.
Companies should also determine payment options for tests. Unlike tests ordered by healthcare providers, employer-required COVID-19 tests are not covered by the government. According to the New York Times, doctors could charge $50 to $100 a test. The question of who is responsible for payment is not simple. Insurers who may cover occasional employee tests may not do so for regular, group testing. Employers should decide up-front who will cover the cost of testing, whether incurring the entire cost, sharing the cost with an employee or placing the full payment responsibility on the employee.
With a solid plan in place for collecting immunization and testing records, along with robust record-keeping, employers can get prepared for federal reporting. Many of the reported items will be found in the records that you are keeping. However, for staff not used to regular federal reporting mandates, this time can serve as a primer to learn the requirements and timing. Employers will be following a temporary emergency standard to be issued by the United States Department of Labor’s Occupational Safety and Health Administration (OSHA). The order will require proof of employee vaccinations as well as weekly testing and reporting of results for those employees who cannot or have yet to receive the vaccine. Employers should reference the CDC website as a source for additional information.
The government’s announcement about full vaccination requirements and upcoming booster availability will result in employee questions. With employee recruitment and retention as ongoing challenges, this is an opportunity for employers to demonstrate that employee health, safety, and peace of mind are top priorities. A full, proactive communication plan will ensure that employees are informed and engaged. Creating a comfortable space for questions – whether electronically, or during a companywide meeting – will help keep information and reassurance flowing.
Andrea Pickett is the vice president of customer success at Prescryptive, where she oversees all aspects of customer relationships and operations to ensure every customer achieves positive benefits from Prescryptive’s products and services. Prior to Prescryptive, Andrea spent over 20 years working with healthcare technology and pharmaceutical companies in various customer-facing leadership roles including account management, product development, sales, and marketing.
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