COVID-19 Vaccines: Step-by-Step Guide for Community Action

This step-by-step guide is intended to help the Community Action network be nimble with respect to their approaches to vaccines in the workplace and maintaining compliance with applicable federal mandates issued by Head Start and the Centers for Medicare & Medicaid Services (CMS). Various legal challenges to the mandates, including to the OSHA Emergency Temporary Standard and the Head Start vaccine mandate, have resulted in many CAAs no longer being subject to any federal vaccination, testing, or masking requirements. However, such CAAs may, subject to their state and local laws, voluntarily adopt their own workplace rules regarding COVID-19 vaccines, tests, and masks.

This guide helps CAAs subject to vaccine mandates as well as those voluntarily adopting a mandate think through their implementation and enforcement procedures. We describe the planning process your CAA should consider as you develop and update your COVID-19 approach. We also provide template policies and additional resources to assist your CAA in preparing for and implementing federal mandates and your own workplace rules. We will update this resource as additional guidance is issued and legal developments arise.

1. Identify if a mandate applies

2. Determine timeline

3. Identify an approach

4. Adopt written vaccine policy

5. Review leave policies

6. Maintain OSHA reports

7. Review accommodations process

8. Understand enforcement + penalties

9. Additional resources

Template Documents

For CAAs who have employees who are not covered by any federal mandate, the sample policies below are not required. If your CAA chooses to voluntarily implement one of these policies, note that they are modeled on the now-defunct OSHA Emergency Temporary Standard issued in 2021. Since this mandate is no longer in effect, CAAs may modify the provisions of the policies to the extent allowed by other applicable federal mandates and state and local laws.

CAAs subject to the Head Start Rule:

  1. Mandatory Vaccination Policy for All Employees and Individuals Covered by the Head Start Mandate (Head Start-Compliant) (updated February 4, 2022)
    This template is for a CAA seeking to mandate vaccinations for all employees (i.e., both individuals covered and not covered by the Head Start Rule)).
  2. Mandatory Vaccination Policy Only for Individuals Covered by the Head Start Mandate (Head Start-Compliant) (updated February 4, 2022)
    This template and template #3 below are intended to be used together, and are for a CAA seeking to divide its workforce into two groups: (1) individuals covered by the Head Start Rule; and (2) employees who are not subject to the Head Start Rule. This template mandates vaccinations only for individuals covered by the Head Start Rule.
  3. Vaccination or Testing and Face Covering Policy for Non-Head Start Employees (Head Start-Compliant) (updated February 4, 2022)
    This template and template #2 above are intended to be used together, and are for a CAA seeking to divide its workforce into two groups: (1) individuals covered by the Head Start Rule; and (2) employees who are not subject to the Head Start Rule. This provides employees who are not subject to the Head Start Rule with the option of undergoing weekly testing in lieu of getting vaccinated, as permitted by state and local laws.

CAAs not subject to any federal vaccine mandate but want to voluntarily adopt a COVID-19 vaccination policy:

  1. Sample Vaccination or Testing and Face Covering Policy for All Employees (updated February 4, 2022)
    This template is for CAAs that want to require employees to either get vaccinated or undergo weekly COVID-19 testing in lieu of vaccination, as permitted by their state laws.
  2. Sample Mandatory Vaccination Policy for All Employees (updated February 4, 2022)
    This template is for CAAs that want to adopt a vaccine mandate for all employees, with no option to test weekly in lieu of vaccination, as permitted by their state laws.

Federal Guidance

CAPLAW News Alerts

This resource is part of the Community Services Block Grant (CSBG) Legal Training and Technical Assistance Center. It was created by CAPLAW in the performance of the U.S. Department of Health and Human Services, Administration for Children and Families, Office of Community Services, Cooperative Agreement Award Number 90ET0467-03-C3. Any opinion, findings, conclusions, or recommendations expressed in this material are those of the author(s) and do not necessarily reflect the views of the U.S. Department of Health and Human Services, Administration for Children and Families.