The next phase of COVID-19 includes the introduction of the vaccine. In addition to the protocols employers introduced to ensure safety among employees, it is time to address how your company will establish a policy regarding the vaccine and the potential vaccination of your workforce. Oswald Companies and Oswald Labs continue to track the latest developments to provide you the guidelines and resources to assist with employee communications.

As the FDA has recently issued emergency use authorization of the COVID-19 vaccine and the approval of additional COVID-19 vaccines is on the imminent horizon in the U.S., we know employers are wondering what, if any, steps they should be taking now to prepare their workforce.

Oswald Labs provides some suggestions/recommendations below based on current information available. We hope this will be helpful as we move forward into this uncharted territory.

1. Policies for COVID-19 Vaccination: It will be important to create and/or review and update your company policies regarding vaccination as necessary. Consider creating a committee to devise your strategy regarding vaccination for employees. Some issues to think about when creating/revising policies concerning vaccination for COVID-19 include:
   1. Educate, inform or recommend the vaccine: Will your company simply recommend or require all employees to receive the vaccine? If you already have a process in place for the flu vaccine, it may make sense to create a similar policy for COVID-19.
   2. Exceptions/accommodations: Expect and prepare for exceptions and accommodations for receiving the vaccination, which could be based on religious and/or health-related reasons. Establish criteria and safety measures for case-by-case analysis of exceptions/accommodations to protect exempt employees and the remaining workforce. Consider any employee relations issues that may arise—and how they would be handled—in advance.
   3. Confidentiality: If not already in place, develop a policy to ensure that employee medical files are kept separate from general personnel files and treated with the appropriate confidentiality.
   4. Vaccine priority: Consider whether certain employees might receive priority under your policy if there would be a shortage. Ensure that your decision isn’t based on discriminatory or impermissible considerations under the law. Closely monitor recommendations from local, state and federal government regarding prioritization for COVID-19 vaccine.
2. Communication: Clear communication and dissemination of information concerning COVID-19 vaccination to employees will be critical. Some considerations include:
   1. If mandating that all employees must be vaccinated, be sure to consider the rationale for this decision, as well as what information should be included in providing this message to employees. In some cases, employers may need to consider updating job descriptions with essential functions that may require a mandatory vaccination.
   2. Consider creating a specific point of contact for employees who have questions about the vaccine and the vaccination process. Identify who within the company would be best equipped to serve as a central resource for providing new information and updates, as well as answering questions. Ensure that this person (or persons) is provided the most recent information to relay to other employees. Determine how employee requests for exception/accommodation will be managed and by whom.
   3. In order to inform those in high-risk categories, consider sending an educational flyer to help employees understand who will be prioritized for vaccination (once that has been finalized). For privacy, any educational material should be provided to all employees versus targeting specific groups. At the present time, the CDC has indicated that the following will be considered for early vaccination:
      1. Healthcare personnel
      2. Workers in essential and critical industries, i.e., those who are considered part of America’s critical infrastructure
      3. People at high risk for severe COVID-19 illness due to underlying medical conditions
      4. People 65 years and older
3. Cost and Access:
   1. During the national public health emergency period, health plans must cover all authorized COVID-19 vaccines, with no cost to the member, including the cost of administration when the primary purpose of the office visit is for the vaccination. Contact your insurance broker with any additional questions.
   2. Discuss plans for administration and employee access. Consider vendors and vaccination providers who may be available to provide on-site services.
   3. Talk with your local and/or state public health department to understand what resources may be available to support strategies for vaccination. Some companies/organizations may be eligible to become Closed Points of Dispensing.
4. Continue COVID-19 Safety Practices: Although vaccination across the U.S. is imminent, employers must remain vigilant in creating a safe working environment by requiring employees to wear a mask, maintaining a social distance of at least 6 feet, and washing hands frequently.

Insurance carriers are releasing more detailed announcements regarding the vaccine and how the vaccine will be covered for employer and individual plans, Medicare plans and Medicaid individuals. In general, members of an insurance plan will have a $0 cost-share (co-payment, coinsurance or deductible) for FDA-authorized COVID-19 vaccines.

Members will be able to receive the vaccine during the national public health emergency declared by the U.S. Department of Health and Human Services. The current national public health emergency is scheduled to end Jan. 20, 2021.

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Note: This communication is for informational purposes only. Although every reasonable effort is made to present current and accurate information, ISBC makes no guarantees of any kind and cannot be held liable for any outdated or incorrect information.