Special Edition – COVID-19 ETS: Vaccine & Testing Tracking

Published October 1, 2021
President Biden’s September 9th Executive Order mandating certain employers to track Vaccine & Testing Status has many of us asking questions. As the nation awaits regulation at the Federal and State levels, BTR is here to offer what we know today.

Who Is Impacted?

  • Federal Executive Branch workers
  • Employees of organizations contracted with the Federal government
  • Private Sector Employers with 100+ employees
  • Educators employed by DoD facilities
  • Employees of HealthCare facilities that receive Medicare and Medicaid reimbursements

What is the actual Mandate?

Employers will be required to enforce COVID-19 vaccination or weekly COVID-19 testing among their employee populations. Once the regulation is published, the rule will last for six months, at which time a permanent measure will need to be drafted. Employers will likely have 15-30 days to develop compliance within their organization after the mandate is published.

OSHA Adoption

The US Labor Department’s Occupational Safety and Health Administration has been specifically tasked with adopting the mandate to their general guidelines and policies. OSHA is expected to issue the new rule under a 1970 law which allows for an expedited “emergency temporary standard.” The new rule will act as an extension of OSHA’s charge to keep America’s workplaces safe and updates are available on the OSHA website.

Could there be Penalties?

Yes – non-compliant employers could face penalties up to $14,000 per violation. Employers may also need to factor in the cost of any legal fees or other risks associated with non-compliance.

How to Prepare

  • Review your employee handbook/employment contracts and begin drafting changes to include vaccine policy
  • Enact policies to ensure all employees are treated equitably
  • Establish specific timelines and goals for compliance across your organization
  • Consult with legal counsel to ensure procedures and implementation are executed properly and communicated effectively
  • Talk with your current technology providers to assess solutions for collecting proof of vaccination, validation processes, confidentiality, etc.

How is HR Technology Responding?

Vendors across the industry are launching tools to track vaccine and/or testing status in their systems. Below is a list of what we know as of the time of this blog post’s publication:

  • ADP’s Return to Workplace solution offers the ability to track proof of vaccination as well as COVID-19 test results.
  • Alight’s Verify Solution is expected to be live in October of this year, giving organizations the ability to certify and track vaccination status with employee access to load proof of vaccination and test results, as well as data analytics for administrators.
  • Bswift’s Attest solution teams up with CVS Pharmacy to provide a compliant and secure front-end for employees to upload their vaccination cards or track their ongoing test results.
  • Ceridian’s Dayforce Employee Safety Monitoring solution is a business continuity planning technology that will help employers track risk to employees and operations and communicate with speed and accuracy.
  • iSolved’s Employer Toolkit includes guides, forms, checklists, fact sheets, and posters to support safe workplace practices regarding COVID-19. iSolved also advised that account managers can support with setting up client needs for vaccine/testing tracking.
  • Paycom advises they can set up custom fields and certifications through their LMS Module.
  • Paycor’s Immunization Tracker solution helps business leaders manage and track the immunization status of their employees. Workers can upload proof of vaccination, or a negative COVID test directly to the system, allowing HR leaders to run a report of status across the organization.
  • Paylocity is able to track certifications now and will be launching a dedicated module in the coming weeks.
  • PlanSource offers a solution for tracking vaccine records, test results, and more in both mobile-enabled and desktop formats. Administrators can also report the data as needed.
  • Proliant can track vaccine/testing status through the HRIS module and can also create custom events.
  • Smartlinx can handle vaccine/testing status tracking much in the same way as they do credentialing. This includes proactive notifications and monitoring for expiration dates.
  • UKG is able to save vaccination proof cards within documents and can create custom fields for vaccine/testing status tracking.
  • Unum’s Vaccine Verifier solution allows employers to verify vaccination status, manage exemptions, and oversee testing compliance. A similar solution will also be available through Colonial Life, an Unum brand.

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 BTRProjects@bentechre.com 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 www.cdc.gov/vaccines 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

Holli Brummett supports BTR as the Business Development Coordinator, focusing on new opportunities and business development for the BTR Extend Division. Holli brings to the team several years of Benefits Administration experience on multiple systems, working with broker teams as well as employers across many industries, including manufacturing, school districts, hospital systems, and more.