Vaccine mandates for COVID-19 continue to evolve and change. Organizations are facing pressure from various internal stakeholders as well as federal and state agencies that often contradict each other.  COVID-19 rates are declining in the US, which has translated into decreased mandates and the lightening of previous requirements. With that said, some areas of the world are experiencing a renewed surge, which may signal a pendulum swing is coming related to vaccine and mask mandates. Only one thing seems certain – mandates and COVID-19 requirements will keep changing, and employers must design programs, policies and tools that continue to be flexible.

Regardless of your organization’s current strategy surrounding vaccines, testing, and masking protocols, it is critical to consider tracking systems, communications, incentives, and equity.

Vaccine tracking systems

While public tools like this COVID-19 tracker are available, many organizations are wondering how they can record and track vaccine and booster status if that is a requirement for employees. Without a tracking mechanism, policies will be difficult to enforce. However, collecting vaccination status and test results is considered confidential medical information. It is important to understand the privacy factors and risks involved in housing such information. Whether using a third-party platform or something internal, make sure you cover your compliance bases.


No matter the course of action you take, be prepared to deal with opposing viewpoints. If you are taking a hard vaccine mandate stance, does that mean employees who do not comply will be terminated? Are you offering exemptions and if so, how easy are those to get? Are you at risk of being sued over these policies? Alternatively, if you are not implementing a vaccine mandate or similar masking/testing requirement, it will be important to make accommodations for employees who feel unsafe in such an environment. Perhaps separate workspaces need to be ensured, or expanded remote working policies put into place. Whatever your corporate decisions, plan to over-communicate. If your programs and policies are fluid, many employers have found an information hub useful so employees know where to look for the most current information.


In 2021, incentives for vaccinations were popular. State governments facilitated cash-based lotteries. Honda offered cash incentives to employees, and Kroger offered both cash and free grocery incentives. In true Massachusetts form, the state offered free Dunkin’ iced coffees to those getting vaccinated. Now, incentives have petered out a bit, but Arkansas is still handing out a $20 lottery ticket to anyone who gets a shot, and New York is offering the chance at ski passes to those who get a booster. The bottom line here is that vaccination and booster incentives are fair game. Just keep in mind that at this stage in the game, they may or may not be effective.


The walk back of the federal OSHA law means a patchwork of policies exist between states. If your organization has employees in multiple states, make sure you are aware of the legislation across the board. As an extreme example, be prepared to develop a policy strategy for employees in states where vaccine mandates are prohibited even for private companies. A uniform policy may not be feasible but ideally you should set corporate requirements and then adjust only where required by law.

The vaccine discussion has been a hot topic for over a year and we are not done with it yet, as risk factors keep changing.  If you have questions about vaccine compliance, communications, accommodations, or reporting, please get in touch with Spring and we would be happy to help. Our client, edHEALTH, and its member schools, have effectively navigated the evolving and charged landscape of COVID-19 policies, which have been even more complicated in the realm of higher education. Here are some additional tools available to help you out.