Federal Vaccine Mandates: Step-by-Step Compliance Guide for Community Action
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. We also provide template policies and additional resources to assist CAAs in preparing for and implementing the mandates. We will update this resource as additional guidance is issued and legal developments arise.
11/17/21 update: OSHA has suspended implementation and enforcement of the OSHA ETS pending the outcome of current litigation.
9. Additional resources
- CAPLAW: Template Vaccination or Testing and Face Covering Policy (OSHA-compliant) (issued November 12, 2021)
- CAPLAW: Template Mandatory Policy (OSHA- and CMS-compliant) (issued November 12, 2021)
- CAPLAW: Template Medical Exemption Request Form – COVID-19 (issued October 29, 2021)
- CAPLAW: Template Religious Exemption Request Form – COVID-19 (issued October 29, 2021)
- OSHA: Resource Page on OSHA ETS
- CMS: FAQ on CMS Mandate
- EEOC: What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws
- Head Start: New Standards for Vaccination and Masking to Reduce Transmission of COVID-19
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.