The Vaccine Mandates: What They Mean for Your Credit Union

Posted: Sep 16, 2021 | Author: Cornerstone League
COVID-19  COVID-19 Vaccine 

President Joe Biden issued a COVID-19 Action Plan, “Path out of the Pandemic,” which includes an effort to reduce the number of unvaccinated Americans by using regulatory powers and other actions to increase vaccination numbers. Aspects of the plan that may impact credit unions include:

  • Requiring all employers with 100+ employees to ensure their workers are vaccinated or tested weekly;
  • Requiring vaccinations for all federal workers and for contractors that do business with the federal government; and
  • Requiring employers to provide employees with paid time off to get vaccinated.

Please note that Cornerstone is anticipating further guidance from the federal government regarding how these mandates may impact credit unions. Please stay tuned for more detailed guidance as soon as we have more information. For now, the following is our take on the matter. 

Required Vaccinations for Large Employers

Regarding the large employer vaccination requirement, at this point we are still awaiting the details. The Department of Labor’s Occupational Safety and Health Administration (OSHA) is developing an emergency rule (referred to as an “emergency temporary standard”) that will require all employers with 100 or more employees to ensure their workplace is fully vaccinated or to require any unvaccinated workers to produce a negative test result on at least a weekly basis before coming to work.

Many questions are still outstanding, such as whether this will impact employers with the requisite number of staff in one location or if it would also apply to employers that have over 100 employees spread out across multiple locations.

The timeline for vaccinations will be included in the emergency rule and is therefore unknown at this time.

Required Vaccinations for Federal Contractors

The President’s order regarding federal contractors will require executive departments and agencies including independent establishments subject to the Federal Property and Administrative Services Act to ensure that contracts include a clause that employees of any  contractor and any subcontractor be vaccinated.

The timeline for federal employees and contractors to be vaccinated is 75 days.

Federally insured credit unions have been deemed to be “federal contractors” in some contexts, such as the Department of Labor’s Affirmative Action plan rules. We will have to wait for further guidance to know for sure if credit unions will be considered federal contractors for the vaccination order purposes. It appears that the order focuses more on actual contracts rather than on being federally insured, so perhaps not. However, any credit union with branches on federal property and serving a field of membership tied to the federal government is more likely to be considered a federal contractor for vaccination purposes. 

Time Off for Vaccinations

OSHA’s emergency rule will require employers with more than 100 employees to provide paid time off for the time it takes for workers to get vaccinated or to recover from vaccination side effects.

Cornerstone will send out a special alert when we have more information on these important issues.

Questions? Contact Suzanne Yashewski at or call Information Central at 800-442-5762, ext. 8515.


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