Current Status of Federal COVID-19 Vaccination Mandates

To assist in keeping up with the current on status on each mandate, please refer to the summary below. Note that this issue continues to evolve under each of the three separate mandates. 

The GBS Compliance will continue to keep you updated. In the meantime, employers who are affected should prepare to comply by the effective dates.   

Private Employers with 100+ Employees

Type of Rule

OSHA Emergency Temporary Order

Effective Date

Originally December 5, 2021 and January 4, 2022

Moved to January 10 , 2022 and February 9, 2022

Current Status

Not effective

Federal Court stay in place per the U.S. Supreme Court decision on 1/13/22

Steps / Recommendations for Employers

Employers could continue preparations to comply with the mandate in event stay is lifted or could postpone preparations until the merits of the mandate are decided through the federal court system.

Health Care Workers Employed by Employers who Participate in Medicare / Medicaid Programs Including Providers and Suppliers

Type of Rule

CMS Rule

Effective Date

Originally December 5, 2021
and January 4, 2022

Now January 27, 2022 and February 26, 2022 (for states with no stay)

Now February 14, 2022 and March 15, 2022 (for states with a lifted stay)

Current Status

Effective for all states

There was no federal court stay for certain states but for the remaining states, the U.S. Supreme Court lifted the stay on 1/13/2022

Steps / Recommendations for Employers

Affected employers in all states should prepare in order to meet the current deadlines.

The first date represents the deadline for the first dose, and the second date represents the deadline for the second dose (and the single dose vaccine)

There are technically different (later) effective date for states that were under the stay, these states are: Alabama, Alaska, Arizona, Arkansas, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Montana, Nebraska, New Hampshire, North Dakota, Ohio, Oklahoma, South Carolina, South Dakota, Utah, West Virginia and Wyoming.

All Federal Workers and Contractors including all Employees Working on or in Connection with Covered Federal Government Contracts and Subcontracts

Type of Rule

Safer Federal Workforce Taskforce Guidance

Effective Date

Originally December 8

Moved to January 4, 2022

Moved to January 18, 2022

Current Status

Federal Court stay for all states

Steps / Recommendations for Employers

Affected employers should continue preparations to comply with the mandate in event stay is lifted

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