President Biden’s administration recently announced its Path Out of the Pandemic action plan which included specific guidance around a COVID-19 vaccine mandate.
The action plan calls for employers with 100 or more employees to require employees to be vaccinated or submit to weekly tests, as well as requiring vaccinations for federal employees, contractors, and hospitals receiving federal financial assistance. OSHA is required to issue vaccine/testing rules as part of an Emergency Temporary Standard (ETS). Until OSHA issues the ETS, many employers are scrambling to understand how the mandates will affect them, what employers should know if considering a surcharge, and how they might prepare for compliance.
In this webinar, held on Tuesday, November 16, consultants from Current HR, DBL Law and Blue & Co., LLC, addressed the best practices for handling the OSHA mandate, CMS Interim Ruling, and surcharge issues. Topics disccused included:
- Who is subject to the vaccine mandate and how employees will be counted
- Recommendations on creating policies and procedures
- Best practices to develop, communicate, implement, and enforce institutional vaccine policies and procedures
- Concerns surrounding testing requirements, such as cost and timing
- Considerations for surcharges as part of a wellness program, implementation of surcharges, and potential ACA affordability issues
- Reasonable accommodations and exemptions
- HIPAA considerations
- What steps can you take to put yourself in the best position to comply with the expected ETS
Charlie Vance is the CEO of Current HR, a licensed attorney in the state of Kentucky, and a SHRM-certified human resources professional. Vance helped found Erigo Employer Solutions, a Northern Kentucky PEO, in 2011 and served as CEO until 2020. Under his leadership and direction, the organization was recognized as an Emerging 30 company in 2015, 2016, and 2017 and grew to $33 million in annual revenue. Vance is active in the community. He is appointed by the Covington City Commission to its Audit Committee and has served on several nonprofit boards and committees including the Northern Kentucky Chamber of Commerce, Covington Partners, the HealthPoint Family Care Foundation, Brighton Center Technical Advisory Board, the Horizon Community Fund Steering Committee, and the National Association of PEOs (NAPEO). He is the recipient of Legacy’s 2017 Next Generation Leader Award for Entrepreneurship, received Eastern Kentucky University’s Young Alumni Award in October of 2017.
Kelly Holden is chair of DBL Law’s Employment Law practice which represents private and public employers in all facets of employment law. Her practice includes advising clients on compliance with various employment matters and providing in-house training on such issues. Kelly has experience working with agencies such as EEOC, DOL, DOJ, Kentucky Commission on Human Rights, Kentucky Labor Cabinet, Ohio Civil Rights Commission, Ohio, Kentucky and Indiana unemployment commissions, as well as litigating cases in federal and state courts. She also drafts employment and non-compete agreements, with an emphasis on health care provider and physician agreements. Kelly advises companies on I-9 compliance, performs I-9 audits, conducts harassment investigations, drafts employee handbooks and employment policies. Although Kelly represents private and public entities across all industries, she particularly focuses on non-profit clients, educational institutions and healthcare entities.
Amanda Dennison joined Blue & Co. in August, 2011 as an Administrative Assistant in the Lexington, Kentucky office. In August 2014, Amanda became a Revenue Cycle Consultant and moved to the Louisville (Healthcare) office.Amanda is a valued member of the firms Revenue Cycle team, with a focus in Rural Health Clinics, and physician offices. Amanda has significant experience in the RHC certification process from application through implementation, and has worked frequently to setup RHCs in Kentucky, Indiana, Ohio, and Florida, to name a few. Amanda is a Rural Health Certified Billing Specialist (RH-CBS) through the Association for Rural & Community Health Professional Coding (ARHPC), as well as a Certified Rural Health Clinic Professional through the National Association of Rural Health Clinics (NARHC) supporting her knowledge of the RHC landscape.