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    EEOC Guidance on COVID-19 Vaccinations

    On May 28, 2021, the U.S. Equal Employment Opportunity Commission (EEOC) issued updated COVID-19 guidance concerning vaccinations in the employment context. The highlights are:

    * Employers may require employees who physically enter the workplace to be vaccinated for COVID-19, as long as employers comply with the reasonable accommodation provisions of federal and state anti-discrimination laws (e.g., accommodations required due to a disability or a sincerely held religious belief).

    * Employers may offer incentives to employees to voluntarily provide documentation or other confirmation of vaccination obtained from a third party (e.g., doctor, pharmacy), but such information must be kept confidential and stored separately from an employee’s personnel file.

    * Employers that are administering vaccines to their employees may offer incentives for employees to be vaccinated, as long as the incentives are not coercive.