UPDATE (5/28/21): EEOC Authorizes Employee Incentives for COVID-19 Vaccination

Exciting news for employers! The EEOC has just released fresh guidance on incentivizing COVID-19 vaccinations. They've made it clear that employers can offer incentives to employees for getting vaccinated. While the incentive cannot be coercive, it can be a reward or penalty. The guidance reflects the seriousness of COVID-19's impact in the workplace. If you're eager to boost your COVID-19 vaccination program or enhance your response to infectious diseases, contact us for a free consultation. Keep your workforce safe and informed!
covid-19 vaccine bottle closeup

The Equal Employment Opportunity Commission just released new guidance to employers today.  The new guidance deals directly with the question of whether employers can offer incentives to employees in connection with COVID-19 vaccines.  More specifically, the EEOC explores the circumstances under which an employer can provide extra benefits or payments to employees who agree to be vaccinated against COVID-19.


The conclusion that the EEOC reached is that under the provisions of both the ADA and GINA, employers can offer incentives to employees who agree to be vaccinated, as well as those who agree to provide documentation of their vaccination status.  The agency indicates that the incentive cannot be so large as to be coercive, but it can be an incentive nonetheless.  The agency does not provide any guidance with respect to what would be an unduly large/coercive incentive program.

Rewards or Penalties:

Interestingly, the EEOC indicates that incentives can be rewards or penalties—implying that employers could penalize employees who refuse to be vaccinated.  However, the agency also expressly notes that employers cannot penalize employees whose families refuse to be vaccinated against COVID-19.

COVID-19 Guidance:

This guidance continues in the pathway of previous agency guidance on COVID-19, with the EEOC clearly recognizing the scope and seriousness of the impact of COVID-19 infections in the workplace.  Based on that impact, the EEOC has granted employers significant leeway in evaluating and screening employee health and supporting COVID vaccination programs and related measures.  As with any occupational health consideration, programs must be implemented uniformly that do not unfairly single out or target any individual employee or any protected classification group of employees.

For more information on COVID-19 vaccination programs or how to improve your company’s resilience in the face of airborne infectious diseases, contact our team today for a free consultation.



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Dr. Michael Tenison

A series of notable accomplishments distinguish Dr. Michael Tenison’s career in medical operations and healthcare management:

  • Successfully led medical operations at a national healthcare provider, focusing on optimizing healthcare delivery and patient outcomes.
  • Oversaw the regional medical practices in key markets like Oregon and Northern California, ensuring consistent, quality medical care and service delivery.
  • Demonstrated exceptional leadership in building and mentoring a large medical provider team, enhancing team performance and patient care standards.
  • Implemented strategic company policies and protocols, significantly improving center efficiency, clinical quality, and patient experiences.
  • Played a pivotal role in financial planning and identifying growth opportunities for healthcare services, contributing to the organization’s overall success.
  • Served as a primary point of contact for regional employer clients and insurance companies, fostering strong relationships and effective communication.
  • Maintained high medical care and case management standards through diligent supervision, chart audits, and performance metric analysis.

Dr. Matt Feeley

Dr. Matt Feeley is a renowned figure in military aviation medicine, with a robust background in occupational and environmental medicine from the Johns Hopkins Bloomberg School of Public Health. 

  • Former Naval Flight Surgeon, exemplifying his expertise in aerospace medicine and commitment to military health.
  • Served with distinction at NSA Bahrain and HSM-37, earning the COMPACFLT Flight Surgeon of the Year award for exceptional medical service.
  • Supported U.S. Marines VMFA-323 aboard the USS Nimitz, MACG-38, and VMU-3, demonstrating versatility and leadership in diverse medical environments.
  • Broad interests and significant contributions in global health, corporate medicine, and aerospace medicine, highlighting his multidisciplinary approach.
  • Proven track record as a dynamic leader, well-equipped to face the challenges in a fractional medical directorship role with innovative solutions.

Dr. Glen Cheng

A physician-attorney with a dedication to healthcare innovation, informatics, and digital health.

  • Currently spearheads employee health protection and promotion within the VA Pittsburgh Health Care System.
  • Trained in residency at Harvard, achieving board certification as a physician; also a licensed patent attorney with experience as FDA regulatory counsel.
  • Co-founded Acceleromics, a consulting firm providing clinical and regulatory guidance to digital health startups.

Erin Davis

 Chief Clinical Officer at Work Health Solutions, certified in Adult-Gerontology (AGNP-C) and Athletic Training (ATC).

  • Oversees clinical operations and ensures high clinical standards across the company’s national field staff.
  • Former Manager of Clinic Operations and Occupational Health Nurse Practitioner at Stanford University Occupational Health Center (SUOHC).
  • Specialized in treating occupational injuries and illnesses, and provided medical surveillance and travel medicine consults at Stanford and SLAC National Accelerator Lab.
  • Dedicated to sports and occupational injury treatment and prevention.
  • Assistant Clinical Faculty at UCSF, mentoring students in clinical rotations within the Adult Gerontology and Occupational and Environmental Health Program.
  • Holds leadership roles as Treasurer and President Elect of the California El Camino Real Association of Occupational Health Nurses (CECRAOHN), affiliated with the American Association of Occupational Health Nurses (AAOHN).

Dr. Robert Goldsmith

Expert in benefits design and onsite innovation with specialization in the pharmaceutical industry.

  • Previous role as Executive Director for Employee Health at Novartis Services, Inc., leading health services and clinical support.
  • Instrumental in creating an integrated healthcare system at Novartis.
  • Former private practice in internal medicine in Stamford, Connecticut, and Medical Director consultant for GTE Corporation.
  • Transitioned to GE as a Global Medical Director in 2000.
  • Holds a medical degree from Albert Einstein College, an MPH from the University of Connecticut, and completed training at Greenwich Hospital and Yale-New Haven Medical Center.
  • Assistant professor in the Department of Medicine at the Vagelos School of Medicine, Columbia University.
  • Serves as a team physician for high school athletes in Stamford.
  • Published works on occupational health risks, primary prevention, and exercise-induced asthma.