COVID-19 Vaccination Requirements_ HR Blog Southwestern HR Consulting

As many of you have probably heard by now, President Biden announced several initiatives yesterday to require vaccination or weekly testing of employees working in certain industries:

Private Employers

Employees working for private employers with more than 100 employees

Federal Workers

Federal workers in the Executive Branch and employees or Federal contractors

(Federal workers were already covered)

Health Care Workers

Health Care Workers in health care settings that participate in Medicare or Medicaid

(Employees in New Mexico hospitals currently have a similar requirement under a public health order.)

The President also called upon state governments to require the same provisions of teachers and school personnel.

The requirement related to private employers will be mandated through an Occupational Safety and Health Administration (OSHA) rule. It is expected that OSHA will issue an Emergency Temporary Standard (ETS) to implement this provision. The requirement related to Federal contractors falls under the provision of an Executive Order. The Whitehouse also signified that the Centers for Medicare and Medicaid Services (CMS) is taking action to require vaccinations for “workers in most health care settings that receive Medicare or Medicaid reimbursement…” This mandate will also apply to nursing home staff, staff in hospitals and other Medicare/Medicaid settings and covers volunteers and staff who do not provide direct care.

OSHA will also develop a rule requiring large companies to pay for the employees paid time off for the “time it takes for workers to get vaccinated or to recover, if they are under the weather post vaccination.” See for more information.  It is also important to check our state guidelines and requirements as well. 

Please keep in mind, that employees may still request medical or religious accommodation from getting the shot which means you will need to ensure you have a process in place to communicate, receive, review, and make determinations related to these types of exemptions.

Given the daily developments around COVID-19, the information above is subject to change. Southwestern HR Consulting (SWHRC) will be checking for updates and can provide guidance to employers on this issue. Contact us at today, if you would like to use our services to address COVID compliance or other Human Resources related items.

Magdalena Vigil-Tullar

Summarized by | Magdalena Vigil-Tullar


Phone: 505-270-7494 | Email:

PO Box 14274 | Albuquerque, NM 87191

SWHRC - We Keep HR Simple!
SWHRC – We Keep HR Simple!

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COVID-19 Vaccine Federal Regulations Human Resources OSHA