CAPLAW has drafted the following template policies for CAAs subject to federal vaccine mandates from OSHA, Head Start, or both. CAAs should consider which vaccine mandates apply to their organization and review the template policies that correspond with the applicable mandates. We encourage CAAs to consider practical implications for the approaches discussed by the policies and review CAPLAW’s step-by-step compliance guide. CAAs may choose to adopt a single policy for all employees or different policies for different groups of employees. We also recommend working with an attorney licensed in your state to ensure compliance with applicable state and local law.


  1. Template Vaccination or Testing and Face Covering Policy (OSHA-compliant) (updated December 21, 2021)
  2. Template Mandatory Vaccination Policy for All Employees (OSHA-Compliant) (updated December 21, 2021)
  3. Template Mandatory Vaccination Policy for All Employees and Individuals Covered by the Head Start Mandate (OSHA- and Head Start-Compliant) (updated December 21, 2021)
  4. Template Mandatory Vaccination Policy for Individuals Covered by the Head Start Mandate (OSHA- and Head Start-Compliant) (issued December 21, 2021)
  5. Template Vaccination or Testing and Face Covering Policy for Non-Head Start Employees (OSHA- and Head Start-Compliant) (issued December 21, 2021)

Related Resources:

Head Start Vaccine Mandate

Head Start Vaccine Mandate

Tuesday, November 30, 2021, the Office of Head Start's long-awaited vaccination mandate (the Rule) was published in the Federal Register as an interim final rule with comment period. The Rule amends the Head Start Program Performance Standards to require masking for...

Head Start Vaccine Mandate

Webinar on Federal Vaccine Mandates Compliance Guide

CAPLAW recently issued a step-by-step compliance guide to help the Community Action network navigate the employee vaccination mandates announced by OSHA, Head Start, and the Centers for Medicare & Medicaid Services (CMS). In this resource we describe the planning...

Federal Vaccine Mandates: Compliance Guide

Federal Vaccine Mandates: Compliance Guide

This step-by-step compliance guide is intended to help the Community Action network navigate the employee vaccination mandates announced by OSHA, Head Start, and the Centers for Medicare & Medicaid Services (CMS). We describe the planning process your CAA should consider as you develop and update your policies to reflect the new requirements.