Photo by Steven Cornfield on Unsplash
If you want to incentivize your employees to get COVID-19 vaccinations, the Equal Employee Opportunity Commission (EEOC) has issued guidelines.
Of course, cash incentives are taxable. To sweeten the pot in order to give your workers the full amount, remember to increase the gross amount.
But there’s a lot more to consider. It can be a bit tricky.
Caveat
Firstly, a lot depends on where employees get their shots.
There is no limit on the dollar amount, if employees are vaccinated by their doctor or reputable community facility. As in any confidential health information, bear in mind that you must keep their vaccine documentation in confidence.
It’s possible for you to provide vaccinations to employee family members; however, you are not allowed to also give incentives to employees if their family members are also vaccinated. This would violate the Genetic Information Nondiscrimination Act, according to the EEOC.
Coercion not allowed
You or your representative can provide the vaccine with an incentive, but the EEOC warns the incentives cannot be forced on your employees. However, the EEOC has not defined what it means by coercive or forced.
Note: the Internal Revenue Service has rules on providing non-coercive incentives, but the EEOC typically has a narrower requirement.
You incentive options could include non-cash incentives. For example, offering a day off, buying them lunch or dinner, or allowing your fully vaccinated team to go maskless (see the CDC guidelines).
Including gift cards, cash incentives should be set high because you’ll probably want to gross up the amount. Published reports indicate most incentives have been around $100 or less and some as high as $1,000.
Pre-shot questions
As for screening questions before giving the voluntary shots on your property or at another third party’s location, they do not have to be job-related in any way. That’s covered in the Americans with Disability Act.
The EEOC permits you to require employees to be vaccinated before coming to work.
Caution: As you might expect, you are required to make “appropriate accommodations” for any employee who is disabled or who has religious objections to getting shots.
On the other hand, if you can show undue hardship to your organization, an accommodation is not required.
Training
Training is important in this regard. The EEOC has recommended that any supervisor or boss who implement policy be trained on how to deal with requests for accommodation.
For unvaccinated employees, note the following reasonable accommodations:
- Mandating masks be worn
- Keeping a proper distance from others
- Working modified shifts
- Taking regular tests for COVID-19
There’s another caveat: You must consider the diversity of your staff in terms or race, color, religion, sex or national origin.
Why?
There are greater barriers for some demographics. You might have employees who are negatively affected when required to be vaccinated.
Finally, more guidance might be coming from the Office of Information and Regulatory Affairs.
The good news is if you require vaccinations the Occupational Safety and Health Administration indicates you don’t have to maintain records of any side effects.
From the Coach’s Corner, here are related tips:
If You Think You Have COVID-19 Workers, What You Can Do — If you think you have employees with coronavirus in your workplace, there are best practices for you to follow.
HR – Smart Ways to Respond If Employee Gets COVID-19 — Despite taking precautions, millions of people have contracted COVID-19. For employers, the pandemic represents dilemmas if an employee gets COVID-19. One dilemma is how to correctly tell the person’s co-workers. Here’s how.
COVID-19 Lawsuits and How to Protect Your Business — The Biden Administration has called for an Emergency Temporary Standard. This would require you to adhere to a checklist of workplace standards. What you can do.
3 Tips to Reassure Employees about COVID-19 Benefits — The pandemic started prompting many employees to question their health insurance benefits. Take an added step to educate your workers about their options.
COVID-19 Due Diligence: Manage Workers Returning to Work — Employers need to strategize on managing employees in the new normal.
COVID-19 Being Covered under Workers’ Compensation — Across the nation, employees who contract the coronavirus in the workplace are being covered by workers’ compensation. But the rules vary from state to state.
“A leader is admired, a boss is feared.”
-Vicente del Bosque
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