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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.

Employers subject to the OHSA and CMS mandates must implement written policies by December 6, 2021 that comply with applicable rules. In general, these policies will 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.

Employers subject to the Head Start mandate should implement a written policy as soon as possible, as the masking requirement is in effect as of November 30, 2021. In general, this policy will include sections that:

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

See CAPLAW’s template vaccination policies for sample language to include in these sections.

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.