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Employee Vaccination Policy (Mandatory)

Employee Vaccination Policy (Mandatory)


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  • Document Description

    DMCs, along with other types of employers, have a general duty to provide a safe working environment under the federal Occupational Safety and Health Act (OSHA). The COVID-19 global pandemic has created additional health and safety challenges for DMCs.

    Federal administrative agencies have provided guidance for employers regarding COVID-19, including the Centers for Disease Control and Prevention (CDC), the Equal Employment Opportunity Commission (EEOC), the OSHA, and the World Health Organization (WHO).

    Until December 2020, recommended health and safety measures were largely limited to:


    • Maintaining social distancing or physical distancing.

    • Requiring employees to wear face masks or other face coverings, especially when sufficient social distancing cannot be maintained.

    • General cleaning and hygiene measures.

    • Employee health screenings and temperature checks.

    The CDC now also emphasizes the benefits of getting a COVID-19 vaccine as a safe and effective way of preventing illness to oneself and protecting others. As of May 12, 2021, all individuals aged 12 and older in the US are eligible to receive a COVID-19 vaccine. With more widespread vaccine distribution and availability, DMCs may consider including an employee vaccination policy as part of their COVID-19 prevention and mitigation protocols.

    Some DMCs may want to require that employees get vaccinated as a condition of returning to or continuing to work at the DMC's principal place of business or onsite at a program (if permitted to do so in the jurisdictions where they employ workers). Others may simply opt to strongly encourage vaccination on a voluntary basis without requiring it. Employers should consider the benefits and risks of any vaccination policy.

    This policy is for DMCs that want to require certain or all employees to receive a COVID-19 vaccine as a condition of employment, subject to legally required accommodations or other exemptions, and where not prohibited by state or local law.

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