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Center for Disease Control (CDC) Issues Employer Vaccination Program Guidance

March 26, 2021

By Michael Burns, courtesy of SBAM Approved Partner ASE

Last week the CDC published guidance for employer vaccination programs. The CDC is encouraging employers to promote the value of getting vaccinated as soon as possible. This includes building employee confidence toward getting vaccinated, helping determine when employees can get vaccinated, deciding whether onsite or offsite vaccination programs make sense to promote, and suggestions about how to avoid workers unexpectedly having to be off work due to vaccine side effects.

Large employers may consider hosting an on-site vaccination program. This may make sense if the workplace has a large enough number of workers with predictable schedules. It will also depend on whether the employer can enroll with their jurisdiction’s immunization program as a vaccination provider. Check with the local or state health agency on that because staff training may be needed, or alternatively, an enrolled vaccination provider may need to be engaged instead. Space will be needed to set up a vaccination clinic with appropriate social distancing ensured through the entire vaccination process. The CDC plan offers a checklist for employers that see this as an option for them.

Most employers will need to opt for an offsite vaccination program. The plan recommends allowing employees to get vaccinated during work hours. This includes expanding paid time off benefits to cover getting the shot and also allowing the employees to be off of work if they experience some adverse side effects. Side effects may last up to three days for some people. Other suggested vaccination promotions are providing transportation to vaccination clinics, providing information on how to “get in line” for the shot, and stressing the importance of vaccination in company communications. Of particular importance is letting employees know the vaccines should be free of charge, including administration fees. Lastly employers are encouraged to review and remove potential barriers to employees getting a vaccination. These could include policies and practices an employer may have in place that would hinder an employee’s ability to take time off work for the vaccination.

The CDC plan lists some employer best practices to support employee vaccination. These include non-punitive sick leave options such as paid sick leave for employees with signs or symptoms after vaccination. It is also recommended that employers plan ahead and set up a schedule for vaccinations that staggers employee vaccinations as to avoid possible worker shortage that could come from employees experiencing side effects. For two-dose vaccinations, side effects from the second dose reportedly can be more severe. Staggering vaccination will cause delays, and this in turn may reduce vaccination acceptance. It is recommended employers weigh these considerations.

The CDC plan also addresses vaccination mandates and proof of vaccination requirements. The CDC notes that requiring a vaccination will be up to state and local law. The Equal Employment Opportunity Commission (EEOC) states that requiring a vaccine does not violate GINA or any other employment law. Proof of vaccination requirements mandated by employers may not require any medical information as part of the proof. The plan provides for two exemptions from requiring workers to get inoculated:     

  1. There is a medical exemption for adverse reaction (allergic) for certain high-risk individuals (ADA exemption)
  2. Religious belief exemption 

ASE is a member of Protect Michigan Commission Business Leaders Workgroup and supports employers’ efforts to reopen as soon as possible. The fastest way toward this goal is vaccination. For more information that employers can use to support effective communications around vaccination go to the Communications Toolkit at the Michigan Department of Health and Human Services (MHDDS) site at

Michiganders can now begin registering for the COVID-19 vaccination clinic at Ford Field in Detroit. The community vaccination site is set to officially open today, March 24. After the registration process is completed, people who have registered will receive an invitation either by voice or text when it’s their turn to schedule the appointment. The Ford Field site will operate from 8 a.m. to 8:30 p.m., seven days a week, for eight weeks under the federal government’s vaccination pilot program.  Anyone currently be eligible to receive the vaccine is able to make an appointment.

Check out our COVID-19 Vaccination page for more information on how you can start this process.

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