HR Tech 411: OSHA ETS Regulation Update

October 21, 2021

As of the writing of this BTR Bites post, the Status of Vaccine Mandate is nearly ready for release. BTR has the 4-1-1 on HR Tech tips and tricks that we think you should know.

OSHA has submitted the Emergency Temporary Standard (ETS) to the Office of Information and Regulatory Affairs (OIRA) which is a division of the White House Budget Office. Once the review is final, it will be posted on the Federal Register for public access. We expect that once the ETS goes into effect, Employers will have a rather quick (read: SHORT) timeframe in which to prepare their organization for the change.

Recommendations for Preparation 

Start by looking at your current technology.  Connect with your vendors to get a greater understanding of your HR Tech’s capabilities to determine if will meet the needs of your organization. Understanding the functionality that is being offered in response to this ETS will be key to your organization’s successful deployment of the regulation.

BTR is seeing HCMs, Ben Admin Platforms, Carriers, and Point Solutions tout variations of ETS strategies in preparation for the regulation. Here is a list of the strategies we are seeing deployed, and how they will impact employers.

  • Employee Attestations– This is an employee-facing tool that accomplishes two tasks: (1) is the employee experiencing any COVID-19 symptoms, and (2) has the employee been vaccinated.
  • Document Management– Another employee-facing tool that allows for upload of vaccine cards and testing results that can be reviewed by Administrator users.
  • Document Verification– A step above Document Management, this feature will verify the document the employee submits.
    • One thing to keep in mind is that there are different types of verifications: some tools will virtually scan the document to make sure that the picture uploaded is actually a vaccine card or test result, while other tools go even further as to validate that the info submitted is accurate and matches state databases.
  • Waiver Management– This tool allows employees to apply for a vaccine waiver as well as allows the Administrator user to review and approve/deny waiver requests.
  • Custom Fields and Custom Events– Some vendors are leveraging configurable data elements to track employee vaccination status and testing schedules. (This is a more manual approach.)

As your organization considers the options in the market for tracking the regulation, these are some of the questions you may want to answer before committing.

  • What is available to you today in your current system?
  • Is the current available functionality already built into the system?
  • Is there any adaptability for additional guidelines, such as booster shots?
  • How long is the implementation timeline?
  • What is the lift on your HR team for implementation?
  • Is SSO available to support employee adoption?
  • What is the total cost (Fees & PEPM/PEPY) to implement?
  • What analytics will be available for trend analysis and business intelligence?
  • Will the data be easily exportable to a .CSV, Excel, or PDF?
  • What security precautions are being taken to protect PHI?

BTR is closely monitoring this evolving situation. If your organization finds itself in need of a vaccine-or-testing tracking strategy, BTR can help! Feel free to check out our Vaccine Status & Technology Best Practices blog post, or email to ask questions or schedule a consultation.

Please note: This publication is considered a high-level overview of the federal mandate. The requirements may differ based on specific state laws and will continue to evolve. BTR is in no way providing medical advice or guidance on the COVID-19 vaccine or any vaccine or medical diagnosis. If you have questions about whether or not a vaccine is right for you, please consult your physician or go to for more information. Additionally, BTR is not positioned to provide legal advice in any manner, so please consult your ERISA or legal counsel before moving forward with vaccine tracking.


About the Author

Jannette Kresser coordinates BTR’s solution provider relationships and supports operational efficiencies for the Consulting Division. She has over 20 years of experience in project management, contract administration, process improvements, and new technology implementations