Let’s say your CEO walks into the HR department and says, “I need your help. I want an employee vaccination strategy and plan. Please get to work ASAP.” What will your strategy be? Will the goal be vaccination for all employees, including those who continue to work from home or are in hybrid positions? Will you require proof of vaccination? Will the focus be on the “carrot” (benefits, incentives, and other forms of persuasion for being vaccinated) or the “stick” (threat of disciplinary action)?
Have you decided if you will encourage or require vaccinations? How will you handle employees who say, “I have a disability that prevents my being vaccinated,” “I’m afraid of the side effects” or “My religious beliefs preclude my being vaccinated”? What overall action plan will be in your employer’s best interest?
Covering All the Bases
SW HR Consulting recommends an agile, six-phase approach.
Phase 1: Assessment
The first phase is one of learning. What are other companies doing, and what do current employees think about vaccination? SW HR Consulting recommends fielding an anonymous employee survey to gather feedback. “The company can assess what percentage of employees plan on taking the vaccine, what incentives would most encourage them to do so and how beneficial it would be for the employer to offer onsite vaccination, and get an estimate of how many employees the company needs to be prepared to engage within the interactive process for disability and religious reasonable accommodations.” Take care that the survey does not raise unrealistic expectations or create liability, she added.
Phase 2: Decision
Based on the assessment, the company can decide whether to follow the market trend and encourage employees to get the vaccine or to require vaccination as Equal Employment Opportunity Commission guidance allows (with caveats). SW HR Consulting noted that if the company opts for mandatory vaccination, it can strategically choose to require it for certain groups and not others. “For instance, it can require vaccination of employees whose job functions entail contact with the public and/or presence at the worksite, or otherwise where the employee not receiving a vaccine would pose a significant risk of substantial harm to the health or safety of the individual or others.”
Phase 3: Incentives
Employers should consider offering incentives to boost the number of employees taking the vaccine. These could include making the vaccine available at the worksite for free during the paid time or paying for time off and expenses associated with vaccination. SW HR Consulting noted, “Some companies find that proactively offering extra PTO [paid time off] or a small discretionary bonus is a worthwhile investment, compared to unexpected time off due to COVID-related illness and isolation.”
Phase 4: Resources, Including Interactive Process
SW HR Consulting recommends ensuring you have sufficient in-house or contracted HR talent with specialized training to answer questions, engage in the interactive process, and work with leaders to provide reasonable accommodations for needs related to disability or religious belief, such as transfers to positions with lower exposure and lower need for vaccination. Additional competencies needed: handling leaves of absence; benefits administration; workers’ comp, including investigation and presumption of exposure at work; and revision of employment policies and processes.
Phase 5: Communication and Education
“The employer should create a plan to educate everyone about the vaccine,” SW HR Consulting said. “This includes the company’s call to action [encouraging or requiring employees to take the vaccine] and incentives to take the vaccine.” She also recommends providing information on seeking exemptions related to disability and religious beliefs, engaging in the interactive process, and exploring alternative positions were not receiving the vaccination is more acceptable (e.g., 100 percent remote work). Additionally, the employer should provide training and learning tools on communication and conflict resolution with co-workers whose COVID-19 infection control actions are having a negative impact on health, safety, and the collective good at the company.
Phase 6: Implementation and Continuous Improvement
SW HR Consulting emphasizes that vaccination-related decisions and practices are not solely HR’s responsibility. “However, HR facilitates the process, including the continuous re-evaluation and improvement of the practices, with the participation of project teams composed of diverse employees and leaders.” SW HR Consulting urges employers to be open to course correction, considering changes in the external environment (such as trends in vaccination practices in the industry, as well as marketplace, social, economic, scientific, technological, and legal developments) and internal climate (employee engagement, retention, talent acquisition challenges, safety, and health data, and employee behaviors).
