COVID-19 Vaccines: Step-by-Step Guide for Community Action

This step-by-step guide is intended to help the Community Action network be nimble with respect to their approaches to vaccines in the workplace and maintaining compliance with applicable federal mandates issued by Head Start and the Centers for Medicare & Medicaid Services (CMS). Various legal challenges to the mandates, including to the OSHA Emergency Temporary Standard and the Head Start vaccine mandate, have resulted in many CAAs no longer being subject to any federal vaccination, testing, or masking requirements. However, such CAAs may, subject to their state and local laws, voluntarily adopt their own workplace rules regarding COVID-19 vaccines, tests, and masks.

This guide helps CAAs subject to vaccine mandates as well as those voluntarily adopting a mandate think through their implementation and enforcement procedures. We describe the planning process your CAA should consider as you develop and update your COVID-19 approach. We also provide template policies and additional resources to assist your CAA in preparing for and implementing federal mandates and your own workplace rules. We will update this resource as additional guidance is issued and legal developments arise.

OSHA regulations require most employers to report each “work-related” employee COVID-19 fatality or in-patient hospitalization (29 CFR § 1904.39). Employers must report fatalities that occur within 30 days of a work-related exposure, or in-patient hospitalizations that occur within 24 hours of a work-related exposure (see § 1904.39(b)(6)).

Under 29 CFR § 1904.5 Determination of work-relatedness, an employer must consider an injury or illness to be “work-related” if an event or exposure in the work environment either caused or contributed to the resulting condition. If the COVID-19 exposure event likely occurred within the employee’s work environment, and the subsequent illness led to either death or in-patient hospitalization, reporting of the incident would be required. Factors to consider when determining work-relatedness include the employee’s recent schedule or travel, as well as the frequency and duration of contact with other cases in the workplace.

Employers can report COVID-19 fatalities and in-patient hospitalizations by:

  • Calling the OSHA Area Office that is nearest to the site of the incident (see;
  • Calling the OSHA toll-free telephone number, 1-800-321-OSHA (1-800-321-6742); or
  • Submitting information through OSHA’s website at

This resource is part of the Community Services Block Grant (CSBG) Legal Training and Technical Assistance Center. It was created by CAPLAW in the performance of the U.S. Department of Health and Human Services, Administration for Children and Families, Office of Community Services, Cooperative Agreement Award Number 90ET0467-03-C3. Any opinion, findings, conclusions, or recommendations expressed in this material are those of the author(s) and do not necessarily reflect the views of the U.S. Department of Health and Human Services, Administration for Children and Families.