Vax Up, Speak Up, or Stay Home: New York City Issues New Guidance on Vaccination Mandates for Private Workplaces and the Key to NYC Pass

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:

  1. A worker’s record can be a copy of their proof of vaccination or a record of a reasonable accommodation with supporting documentation.
  2. Businesses can create their own paper or electronic record that includes the following information for each worker:
    1. Worker’s name
    2. Whether the worker is fully vaccinated
    3. For workers who submitted proof of the first dose of a two-dose vaccine, the date by which they must provide proof of a second dose (no later than 45 days after submitting proof of the first dose)
    4. Record of reasonable accommodation with supporting documentation
  3. Businesses may check each worker’s proof of vaccination before they enter the workplace each day. They must keep a record of each verification.

By Devjani Mishra, Mark Phillis, Lisa Griffith, Daniel Gomez-Sanchez, Emily Haigh, and Sanjay Nair via Littler

Read full article here.

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