MADISON, Wis.—As COVID-19 vaccination programs roll out across the country, CUNA Mutual is advising credit unions to be very “flexible” with any policies they devise around staff immunization, saying CU executives need to be asking two questions.
“COVID-19 vaccination is a constantly evolving situation,” said CUNA Mutual Group Senior Risk Manager Carlos Molina. “If nothing else, credit unions need to remain very fluid in their decision making here and keep a watchful eye on as many resources as possible—keeping their fingers on the pulse of updated guidance from government organizations, such as the EEOC (U.S. Equal Employment Opportunity Commission). Guidance could change dramatically in just a week.”
Molina is urging credit unions to focus on two “basic questions.”
“Number one, can an employer mandate a vaccination program? Obviously the EEOC has come out and said very plainly that you can, with certain caveats and considerations,” Molina said. “The second question is if you mandate the program, does that make sense for, and fit within, your credit union’s employee culture?”
As vaccination programs begin primarily by treating the elderly and first responders, Molina said credit unions must be prepared to make the right decisions for their organizations when the programs reach down to younger age groups.
As CUToday.info reported, the EEOC has released COVID-19 vaccination guidance, and it is similar to guidance issued around vaccination for the flu. That guidance includes exceptions, such as there must not be a state law that prohibits mandatory vaccinations, as the EEOC only interprets federal law. In addition, employers must consider employee exceptions, such as those with disabilities or sincerely held religious beliefs that might prevent them from getting or being willing to take the vaccine.
But, Molina emphasized, outside of the exceptions, a credit union’s culture will play a large role in setting the direction on any vaccination policies.
“The credit union has to decide if it wants to go down this road. Is it right for its team. And does it make sense for the business,” Molina said.
As CUToday.info also reported, Michigan First CU, in Lathrup Village Michigan, which kept its lobbies open during the entire pandemic, said it will not require employees to get the COVID-19 vaccine.
As vaccination programs continue to roll out, credit unions should monitor news to be aware of any adverse effects from the vaccine, reminded Molina, pointing to limited cases in England, Atlanta and Alaska and elsewhere in which people have had adverse reactions to a COVID-19 vaccination.
“If that starts to happen an increased pace, does it make sense for you to mandate the program?” he asked.
Carlos Molina
Molina said that in speaking with credit unions across the country he has learned some will be mandating employee vaccination.
“We have heard that some may provide employees with paid time off to get the vaccine,” he said, recommending credit unions provide staff with as much education as they can round available vaccines and vaccination programs.
“Dedicated educational resources are important, where people can track what's going on with different vaccines and track what's happening in their states, so everyone's is fully informed,” Molina said.
Molina acknowledged lawsuits could arise as a result of policies mandating employees get vaccinated.
“Credit unions, and all employers, need to make sure that they're working with their legal counsel to fully understand their responsibilities from a federal state and local level related to vaccines and are monitoring guidance from the EEOC and CDC,” Molina said. “And they should be working with their insurance providers to understand any additional obligations.”
One Final Reminder
Moreover, what credit unions must be careful not to overlook, stated Molina, is the fine work they have done to keep employees and members safe during the health crisis.
“Credit unions have done very well in adapting to the new situation, providing alternate work environments for individuals, getting staff to work remotely in a short period of time, establishing a safe work environment for those who remain in the office…If you implement a vaccination program and then have everyone come back into the office on a Monday, and you're not going to continue social distancing and you're not going to have staff wearing masks—you still have to maintain those things and leverage these new established controls that have become part of our daily lives,” said Molina. “I cannot stress enough that credit unions have truly responded as best as the possibly could to this health crisis. But they need to understand a vaccination policy requires a multi-level, multi-layered approach. Just because the majority of your employees choose to get vaccinated doesn't mean you can suddenly abandon all the other controls you put in place.”