COVID-19 Vaccine Verification for Employers: Preparing a Response to New OSHA Requirements
Yesterday’s Emergency Temporary Standard requirements from OSHA are a welcome clarification to many HR, legal, facilities and other leaders struggling to reopen their workplaces safely. At the same time, it is creating a new sense of urgency for nearly every company to ensure that they are compliant with these new requirements ahead of the January 4, 2022 enforcement date.
Understanding the OSHA ETS Requirements
Binding requirements affect private employers with 100 or more full time, part time, or contract employees, but the requirements do not apply to individual employees who work outdoors, from home, or in isolated environments.
• Develop, implement, and enforce a mandatory COVID vaccination policy
• Determine the vaccination status of each employee, obtain acceptable proof of vaccination from vaccinated employees, maintain records of each employee’s vaccination status, and maintain a roster of each employee’s vaccination status.
• Support vaccination by providing employees paid time off to receive and recover from vaccinations
• Make certain reports available for examination and copying to an employee (or to OSHA)
With the January 4th deadline quickly approaching, employers should start getting a plan in place to begin validating their employees vaccine status, among other requirements.
Per the OSHA rule, employers will be generally required to submit the following documentation within 4 hours at the request by OSHA:
type of vaccine administered
date(s) of administration
vaccination status (Full, Partial, etc)
OSHA has compiled a very comprehensive set of material which goes into much more detail than the above highlights. Official documentation can be accessed here: https://www.osha.gov/coronavirus/ets2.
Learning from Others
In working with individuals and organizations over the past few months to provide vaccination verification, we have observed successful principles:
Accuracy - “upload your vaccination card” alone is not sufficient. While paper vaccination cards are imperfect, it’s still necessary to match them correctly to individual employees, and this can be a time-consuming process. Applying technology to analyze what’s on the card is necessary - and it’s been proven to help dramatically.
Privacy - people may be reluctant to share personal health or biographical information, even with their employers (and even when they are happily vaccinated already). Employees do not like having to share a copy of their full ID and all of the birthdate and other information on the vaccination card - and they especially dislike having to share that information with other venues or organizations. Employers need to ensure employees feel in control, and that their information is protected.
Speed - don’t try to force this hopefully once-in-a-lifetime situation into a technology system built to do other things. Companies spend months outfitting legacy HR and ticketing systems that result in poor employee experiences, exhausted administrative staff, heavy costs and PII/PHI risk.
Prioritization - focus on those who are vaccinated first, and handle exceptions differently. Exceptions are limited and often require an investigative workflow to inspect or enforce. By separating a process to validate those who are vaccinated, existing employee ticketing or support channels can focus on the exceptions, rather than the intended rule.
Employee Experience - make it an employee benefit, not a burden. Employees (especially digital natives) want something they can use and control from their mobile phone. Efforts to create one-time file repositories inside traditional corporate systems have led to anger and frustration. The highest satisfaction has come when companies made it easy for employees to share verification with them, and then allowed employees to have a convenient digital card they could use in their local communities as proof of vaccination and ID.
COVID Proof for Everyone
Nametag launched COVIDproof.com earlier this year, in response to growing local mandates for vaccination proof as a requirement before entering indoor spaces. Many small businesses and venues found immediate benefit in this approach and are using it actively today. COVIDproof.com is a free community offering that allows individuals in the US to validate a government ID, matched to a validated profile photo - and matched to a scan of the paper vaccination card. It validates all three pieces of information and puts it into one digital card. It’s secure by design, and users own all their private data. It’s also unique in its universality: it works across the US - regardless of which city or state you live in - or where you were vaccinated. We want to continue helping restaurants, small businesses, athletic venues, and others who are eager to comply with the mandate and get back to business. Unlike most solutions, we give users a single screen to show that both ID and COVID status have been validated. This means quite simply that people can “get inside faster” when a business owner needs to only check one screen.
COVID Proof for Employers?
In recent weeks, we responded to requests from organizations who sought to extend the functionality of COVID Proof to validate the vaccination status of employees, even prior to the OSHA guidance. We’re continuously monitoring OSHA guidance and implementing best practices to ensure compliance.
Get in Touch
Please reach out if you’d like to learn more or if we can be of help as you develop an approach for your company.