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Accommodations, culture, and compliance: Considerations for your COVID-19 vaccination policy

Matthew W. Burr ( is a Human Resource Consultant for Burr Consulting LLC in Elmira, New York, USA.

The U.S. Equal Employment Opportunity Commission (EEOC) of the federal government has issued guidance on COVID-19 vaccination policies for organizations across the United States,[1] providing information related to policies and procedures for organizations large and small. (This guidance continues to evolve, and the EEOC website continues to be updated.) The EEOC protects employees and job applicants from discrimination by employers based on race, color, religion, sex (including pregnancy, sexual orientation, or gender identity), national origin, age (40 or older), disability, and genetic information.

In its new COVID-19 guidance, the EEOC bars employers—including those who have mandatory vaccination policies—from discriminating against an employee or applicant who has a disability or religious reasonable accommodation request, and who makes their request during discussions with the organization; these employees and applicants cannot be automatically disciplined, terminated, not hired, or retaliated against.

This article aims to lay out some important aspects that organizations must consider as the workforce transitions from remote to in-person to remain compliant with the EEOC’s new guidance.

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