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In the ongoing battle to bring the coronavirus pandemic under control, it’s clear that employers in the private sector have an important role to play.
Given the mixed messages and misperceptions that have surrounded COVID and now the COVID vaccines, employers have the authority, credibility and, ideally, the trust, to create effective COVID vaccination programs. Aligning them with their health and wellness strategies makes a lot of sense. But it’s a strategy that’s not without potential pitfalls, so they need to step carefully.
The coronavirus pandemic has presented the United States with a host of challenges, starting with convincing a polarized population that COVID-19 is deadly real and requires consistent observation of safety measures. Today, as we near 500,000 COVID deaths, vaccinations are being distributed, and a 70% vaccination rate will help us reach herd immunity. But obstacles remain due to various hesitations among many.
Employer action can help. COVID vaccination initiatives incorporated within wellness programs are mission appropriate. Vaccinations augment 2020’s COVID safety efforts; combined, they support the goal of keeping employees healthy and on the job. Plus, there’s precedent as many organizations have conducted flu vaccinations through their wellness programs for years.
The complications, however, involve not just the need to market the initiative to the workforce with facts-based, credible information. It’s that there’s not a lot of guidance from regulators on what’s allowed and what’s not, whether the vaccinations are tied to the wellness program or just are a stand-alone HR campaign.
Here are considerations to help organizations move forward effectively.
Start with structural issues, like mandates and incentives
If it seems like an oxymoron to mandate participation in any initiative that is tied to a voluntary health and wellness program, that is a concern – especially since little guidance is available from regulatory bodies like the Centers for Disease Control (CDC), the Equal Employment Opportunity Commission (EEOC) and U.S. Department of Labor (DOL).
Employment law holds employer-mandated vaccinations permissible, for COVID or the everyday flu. Doing so, however, may pose a disconnect with an organization’s culture. Moreover, mandated or voluntary, employers must be mindful of triggering violations of the Americans with Disabilities Act (ADA) or Title VII of the Civil Rights Act. If employees have cause for declining the COVID vaccination, it requires careful questioning of whether and underlying health condition (ADA) or a religious prohibition (Title VII) is behind it. Accommodations may be necessary.
Incentives can pose greater complexity, since there is no published EEOC guidance on incentive limits tied to wellness programs.
Lack of specific guidance from regulators has led 40 business groups to press the EEOC to issue an opinion. It might treat the COVID vaccination as it does the flu, allowing the program to be incorporated into a more formal incentive program that rewards voluntary completion of various wellness activities.
In the interim, outside counsel should be consulted, and a less risky approach to incentivize workers should be considered. For example, collective incentives may be better than individual ones, like department contests to reach 100% vaccination. Individuals who have opted out would be excluded from the headcount.
Educate and validate for optimal employee buy-in
Any number of concerns can keep people from getting vaccinated, from potential side effects to distrust of the science behind the vaccines. Concerns must be acknowledged and validated by sharing factual information from credible sources. Company leaders are influential proponents. Have them get publicly vaccinated and discuss common concerns. Their involvement will set expectations and calm fears.
The more information employees are given, the greater comfort level they will have with vaccinations. Consider developing FAQs about the vaccines and vaccination procedures. Here are key points to cover:
- The science behind the vaccines matters. The Moderna and Pfizer vaccines are unlike typical vaccines. They don’t contain an active virus. They don’t alter one’s DNA. Inoculating a pregnant woman won’t harm the unborn child. It’s helpful to explain how they work, by instructing cells to make a harmless “spike protein” (as in one of the coronavirus’ spikes). The body is thus fooled into thinking “COVID was here,” building an immune response and making antibodies in protection.
- Help people understand what can be expected with both vaccines. They can get the virus after the first shot, but typically, with less severe symptoms. They are less likely to test positive but will have the coronavirus antibodies.
- Those who have an allergic reaction probably have a pre-existing allergy to the ingredients in the vaccines. A checklist should be part of each vaccination, covering allergies, which should dictate whether an individual should get inoculated.
Don’t overlook mental health issues the pandemic has escalated
Between the pandemic and the sea change it’s caused in how we work and live and now the vaccine options and uncertainty around them, the mental health of Americans is hugely pressured. The vaccination initiative poses an opportunity to reinforce the importance of self-care, and how better than promoting all the resources available to support employees’ mental health? The more their mental resilience is bolstered, whether through their health plans or employee assistance programs along with wellness programs, the better off they and employers will be.
Wellness programs that incorporate COVID vaccine initiatives can be an important step forward for organizations, their people and their wider communities as everyone pulls together to put the coronavirus pandemic behind us. HR leaders should be mindful of the risks, though, and in proceeding, be ready to take guidance where they find it.
Employers may find it a smart move to design COVID vaccine initiatives under the auspices of their already established health and wellness programs. There are some risks – on the regulatory front especially, given the dearth of specific guidance on what employers can and cannot do legally. But it’s going to take everyone pulling together, organizations, their people and their wider communities, to take action so we can put the coronavirus pandemic behind us. A good strategy to learn about COVID initiatives and wellness programs is to attend Healthcare Revolution where there will be live sessions with leading industry experts in the field.
