February 2, 2022

What Every Business Needs to Know About COVID Vaccine Mandates

Get the Facts: Understanding the Requirements and Recent News‍

Following the release of OSHA’s comprehensive COVID vaccination requirements, New York City is also establishing one of the nation's strictest private sector vaccine mandates, set to take effect December 27th, 2021.

According to a December 15th release of guidelines by City Hall, all private-sector workers who have not taken action to file reasonable exemptions must provide proof of vaccination of at least one dose of the approved vaccines to their employer. Additionally, individuals only partially vaccinated must submit a date by which they are intending to get their second dose within 45 days of their first dose.

Similar to the OSHA Requirements currently being challenged in court, employers will need to keep a record of each worker’s proof of vaccination. In a unique move for New York, each employer must also attest that they have read the order by the New York City Health Commissioner by filling out and publicly posting a signed affirmation certificate.

This follows COVID Vaccination mandates and statements made at the Federal, State and Local levels around the country. "This is the boldest action in the nation. It is very, very consistent with what we're dealing with right now because we have powerful new threats. We have to answer them,"  Mayor de Blasio said Wednesday, urging the city to get ahead of a new wave of infection. "This is the boldest action in the nation. It is very, very consistent with what we're dealing with right now because we have powerful new threats. We have to answer them".

Be Prepared.


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 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.

Existing Options are Falling Short.


Existing solutions offered by private companies or state and local governments concentrate on three key categories:

Vaccine Passports - commonly used for entry into a restaurant or other indoor space. Some of these allow users to connect into their health records or state vaccination databases, but they all often fall short when someone is vaccinated in a different state or if their vaccination was not included in a state database by the vaccine site who administered the vaccine. Paper vaccination cards are the only universal proof offered to those vaccinated in the US.

Employee Status Tracking Tools - commonly used to replace or supplement an employee HR management system to track employee vaccination status or recent test results. These tools often rely on health questions or in limited cases encourage a user to upload their paper vaccination card, but checking that card for accuracy either does not happen or is offered as a manual, outsourced service at high costs.

Manual Vaccination Card Uploads - commonly custom made by companies on top of existing tools which were not created for this purpose, and again leave the administrative burden on HR administrators to check the information printed on the paper vaccination card.

The challenge companies face is that efforts by some to create a “vaccine passport” was not intended for the needs of businesses to verify and track vaccination status of a community or employee population in a universal way. Having someone show up in-person and flash a vaccine passport does not help with workforce insights or OSHA regulations should they remain in effect. Existing employee or event management tools do not match a government-issued ID card to what’s written on the COVID vaccination card. This creates a significant manual burden or a liability for companies who need accurate employee population data.

A Proven Approach


Automation, accuracy, and universality are critical components that must be considered. We have seen companies using COVID Proof for Employers take quick steps to be able to track vaccination status should they need to adhere to regulations. This allows them to stay agile and keep their options open amidst changing circumstances.

COVID Proof for Employers can help ease the vaccine verification process in several ways:

Increased speed and accuracy: advanced AI is used to match vaccination cards to government-issued IDs

Simplified reporting: view or download a real-time report of vaccination status, built specifically to meet updated US Department of Labor’s Occupational and Safety Health Administration (OSHA) reporting requirements

Privacy at its core: employers don’t need to store vaccination card images, but can still have view access if needed; employees have a user-friendly mobile app (IOS or Android) to keep track of their information

Businesses can set up their dedicated COVID Proof for Employers page in just a few minutes.

To get started, go to COVID Proof for Employers to create a custom partner code for your organization. Once this is established, share a unique verification link with your employees so they can begin uploading their information. You can view or download a real-time report as needed.

Moving Forward with Confidence


Looking at what's next, if we see that the OSHA guidance is upheld and certain businesses do end up having to implement a plan, we’ve found incredible tailwinds in making the process as simple and seamless for employees to safely and quickly share their vaccination status.

We’re continuously monitoring OSHA guidance and implementing best practices to ensure compliance - or collecting the data accurately so companies can be prepared. This could very well be the new normal so companies will need to learn how to continue to be productive while functioning as safely as possible.

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.

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