Preparing HR Technology for the OSHA Vaccination ETS

HR Tech Tips

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.

Recommended 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.

We are 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?


Please note that the information contained in this posting is designed to provide general awareness in regard to the subject matter covered. It is not provided as legal, medical, or tax advice, nor is it intended to address all concerns in your workplace or for public health. No representation is made as to the sufficiency for your specific company’s needs. This post should be reviewed by your legal counsel or tax consultant before use.