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.

In general, a CAA’s vaccine policy would include sections that:

  • Define who is covered by the policy;
  • Outline the vaccination, testing, and masking requirements for covered individuals;
  • Detail procedures to document vaccination status and testing results;
  • Require employees to promptly provide notice of positive COVID-19 test or COVID-19 diagnosis;
  • Remove any employee who received positive COVID-19 test or COVID-19 diagnosis; and
  • Specify disciplinary action for noncompliance.

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 Since this mandate is no longer in effect, CAAs may modify the provisions of the policies to the extent allowed by other applicable federal mandates and state and local laws.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 must require those covered by the Head Start mandate to get vaccinated, but may opt to treat non-Head Start employees in different ways: (1) require them to get vaccinated (i.e., impose the same vaccine mandate that applies to Head Start individuals); (2) allow them to opt to test weekly instead of getting vaccinated; or (3) not require any vaccination, testing, or masking.

CAAs not subject to any federal vaccine mandate, but voluntarily chose to adopt a vaccination, testing and/or masking policy, may use either of the following CAPLAW templates and should work with a local attorney when doing so:

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.