Previously, the EEOC issued guidance stating that employers could require employees to be vaccinated for COVID-19 subject to reasonable accommodations provisions of Title VII, the Americans with Disabilities Act, and other Equal Employment Opportunity considerations. On May 28, 2021, the EEOC provided additional guidance to employers regarding incentives employers can offer for COVID-19 vaccinations. Employers may provide incentives to employees who voluntarily provide documentation or other confirmation that they have been vaccinated. Employers may also provide incentives for employees to get vaccinated so long as the incentive is not so large that it puts pressure on employees to become vaccinated. An employer may offer vaccinations to family members of employees, but may not provide incentives for family members to get vaccinated.
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