There are many things to take into consideration as the guidelines are constantly changing – not just at the federal level but also at the state and local levels. To illustrate, on Thursday, June 10, a few days after you posted this question, OSHA released the Emergency Temporary Standard (ETS) for companies in the healthcare industry. So, if your company is in the healthcare sector, you will need to make sure your practices are consistent with the new ETS. If you are not in healthcare and not covered by the ETS, OSHA also released on the same day the updated COVID-19 guidelines for all other employers. Most of these are voluntary, though certain sections are labelled mandatory consistent with existing OSHA regulations. Several states and localities have also started to require employers to determine the vaccination status of their employees. These include Washington, Oregon, and Santa Clara County in CA. On the other hand, some states are introducing bills that would tend to discourage employers from doing so. Then on Saturday, June 12, a federal court ruling in Texas – which can set a precedent nationwide – upheld the right of private employers to require all of their employees to get the COVID-19 vaccine, except for those who qualify for medical or religious exemptions. Because the situation is so fluid and direction is contingent on many factors such as your industry, your location and areas of operations, the development of such a policy is best undertaken with the advice of your counsel, to ensure that is appropriate to your particular situation.

You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.