COVID-19 Update: Considerations For Employers Concerning COVID-19 Vaccination Programs

Now that the Food and Drug Administration has authorized the Pfizer/BioNTech vaccine for emergency use,¹ and given the probability that one or more other COVID-19 vaccines will be authorized in the coming weeks, employers are anticipating the widespread availability of these vaccines and considering whether to impose mandatory vaccination policies. We discuss the federal law and agency guidance relevant to employers weighing these decisions and offer practical considerations and alternatives.

Key Takeaways

• Currently, there is no federal or state authority directly addressing the question of whether employers may require a COVID-19 vaccine as a condition of obtaining or continuing employment.