Private Employer Update
Step One: Understand the Mandate.
Businesses may not allow any unvaccinated workers to enter the workplace after December 27, 2021 for the duration of the mandate, unless a reasonable accommodation has been made. A “workplace” is “any location — including a vehicle — where you work in the presence of at least one other person.”
Importantly, the new mandate does not apply to workplaces already covered by other federal, state or local mandates, including the Key to NYC Pass, discussed separately below, and the Centers for Medicare and Medicaid Services (CMS) mandate.1
Step Two: Verify & Record Vaccination Status of Employees.
Employers are expected to verify and document the vaccination status of all workers who regularly enter the workplace by December 27, 2021.2 There are three ways to do this:
By Devjani Mishra, Mark Phillis, Lisa Griffith, Daniel Gomez-Sanchez, Emily Haigh, and Sanjay Nair via Littler