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Sage HRMS Compliance Tracking for OSHA Vaccine Mandate

By December 1, 2021December 2nd, 2021No Comments


Sage HRMS users will be able to track compliance for the OSHA ETS (emergency temporary standard) released November 5, 2021, regarding COVID-19 vaccination and testing with a customization built SWK partner Delphia Consulting. This plugin adds onto existing software processes to enable tracking of the key components of the directive, which obligates private companies with over 100 employees working indoors to record vaccinations, testing and related documentation among personnel.

Below is a more detailed explanation of the OSHA COVID-19 vaccine mandate, its requirements, and a few ways Sage HRMS will enable compliance with help from SWK and Delphia:

What is the OSHA COVID-19 Vaccination and Testing ETS?

The Occupational Safety and Health Administration (OSHA) issued the Vaccination and Testing ETS (86 Fed. Reg. 61402) to mitigate occupational exposure and transmission of COVID-19 among large employers, with a conservative estimate of 6500 deaths and 250,000 hospitalizations prevented if guidelines are enforced. OSHA conceptualized the November 5 vaccine mandate on the belief that existing regulations are not sufficient to protect unvaccinated workers from infection, with workplace transmissions accounting for a sizable portion of cases in the US. The compliance deadline as of now is January 4, 2022.

If you are looking for more background or specific requirement information, read the entire documentation here.

DISCLAIMER: On November 12, 2021, the U.S. Court of Appeals for the Fifth Circuit granted a motion to stay OSHA’s COVID-19 ETS. While OSHA has indicated it believes the mandate will eventually be approved after future litigation, as of this writing the Administration has ceased all steps to implement or enforce the mandate “until further court order” per the stay motion.

Vaccine Mandate Tracking Requirements

The OSHA Vaccination and Testing ETS mandates 4 primary requirements: (1) employers will track employee COVID-19 vaccination records, (2) employers will facilitate weekly testing for unvaccinated employees, (3) employers will enforce face covering for unvaccinated employees and (4) employers will promptly remove employees diagnosed with COVID-19 from the job site. Most other required activities revolve around these obligations, including providing up to 4 hours time off for vaccination, tracking which and how many vaccine doses an employee receives, and reporting positive COVID-19 cases in the workplace.

Delphia has compiled a 10-point list of employer requirements taken from the language of the ETS documentation:

  1. Vaccination and Testing Plans
  2. Employee Status Tracking & Proof
  3. Vaccination-related Time Off
  4. Weekly Testing for Unvaccinated Employees
  5. Notice of Positive Test/Diagnosis for COVID-19
  6. Removal of Employees with COVID-19 from Job Site
  7. Face Covering Enforcement
  8. Provide Employees Information on ETS
  9. Work-related COVID-19 Incidents Reporting
  10. Make Records Available

The custom applicant tracking system (ATS) plugin for Sage HRMS directly fulfills points #2-#5, #8 and #10 by providing customized reporting tools and data sets that leverage existing features and integrations.

You can download OSHA’s template for a mandatory vaccination policy by clicking here.

You can also download OSHA’s template for vaccination or testing and face covering policies by clicking here.

Vaccination Tracking & Reporting

While employers have some leeway to customize how they collect the required information for vaccination tracking, there are several essential activities that must be completed to be in compliance. These include:

  • Document proof of vaccination status for employee, including a Vaccination Record Card or other documentation (medical records, etc.)
  • Record vaccination status of employee, including if partial dosage or no vaccination received
  • Record vaccine type (Pfizer, Moderna, Johnson & Johnson) by employee and which dosage received at time of recording
  • Update vaccination status if and when second dosage is received*
  • Record whether employee has a medical or religious accommodation preventing receipt of vaccine**
  • Maintain record of employee vaccination status by roster
  • Treat roster of employee vaccination statuses as medical records protected under 29 CFR 1910.1020

There are still additional items to address for many of these that could make manually tracking each point complicated and time-consuming. However, the most important factor to keep in mind is the maintenance of the roster of employees by vaccination, including whether they are vaccinated or not. This is your central foundation for being able to demonstrate compliance if OSHA audits your records, especially if a COVID-19 diagnosis appears during testing.

*Booster shots are not required to be tracked for the ETS as of the time of this writing

**There are no official exemptions allowed for vaccinations; however, temporary accommodations are allowed for approved religious or medical reasons, but these employees must still be subject to weekly testing

Vaccination Timing

In order to accurately keep track of vaccination status, businesses must also measure the length of time from an employee’s initial dose. This includes the “incubation period” after the first shot of 24 hours, and any time between doses if Pfizer or Moderna. Additionally, employers must grant up to 4 hours of Paid Time Off (PTO) for any activities related to receiving a vaccination, including any appointments to receive the shot itself as well for ancillary tasks like paperwork, etc.


Testing Tracking & Requirements

If an employee if unvaccinated (including if they declare they do intend to receive the vaccine), then they must be subject to testing at least every 7 days, including if they are returning to the workplace after having not been present. Only Diagnostic testing is applicable, while Antibody testing is not. For each test, date, type, result, who administered the test and who read the result must be recorded.

Face Covering Enforcement

Unvaccinated employees, as well as those who are not fully vaccinated yet, must wear an acceptable face covering if working indoors or an enclosed vehicle with another employee. “Acceptable” coverings have to meet 5 guidelines:

  1. Covers nose and mouth
  2. Two or more layers
  3. Secured with ties, loops, etc.
  4. Fits over nose, mouth and chin with no gaps
  5. Has no slits, valves, holes or other openings

Remote & Hybrid Employees

Employees working from home are exempt from testing unless they return to the office, at which point testing within 7 days of entering must resume. This is an important point to remember for hybrid workforces where certain or all employees divide time between onsite and remote work. Employees that have been diagnosed with COVID-19 are also allowed to continued working from home if they chose to, unless they are too sick.

Positive Test & Incident Reporting

If an employee tests positive during in-house testing, or provides a diagnosis given by a healthcare professional, then the employer must give prompt notice to OSHA and quickly remove the employee from the premises if they are onsite. Either action must be taken regardless of employee’s vaccination status on record. Employers are allowed to apply existing sick leave protocols to this procedure, but must always keep employees informed on the exact processes for giving notification.

Penalties for Not Tracking or False Reporting

Companies who fail to follow the guidelines of the ETS will receive a citation with a fine of up to $13,653. However, if OSHA determines the violation was “willful,” this will increase up to 10 times for a total fine of $136,532. There is a possibility that this number will be raised even further in the future depending on upcoming legislation.

How Sage HRMS Enables Compliance for the OSHA Vaccine Mandate

With Delphia’s custom ATS plugin for the OSHA COVID-19 Vaccination and Testing ETS for Sage HRMS, SWK customers will be able to leverage a tailored reporting workflow built using the software’s native tools to enable compliance. The customization achieves this by introducing new codes and tables that allow you to build compliant reporting using mostly the built-in functionality of your software, along with a few integrated features.



Custom Detail Pages

The plugin adds 3 Custom Detail Pages to use to record vaccinations and testing according to their assigned codes. These are:

  • COVID Summary
  • COVID Testing
  • COVID Vaccinations

The Custom Details feature allows users to create additional fields, pages, etc. to incorporate unique data not include out of the box.

UDF Code Tables

The custom ATS offers 7 user-defined Code Tables to track every vaccination by status, type, manufacturer, as well as testing for test type, status, date, process and result. These include:

  1. COVID-19 Test Category
  2. COVID-19 Test Result
  3. COVID-19 Test Type
  4. COVID-19 Testing Status
  5. COVID-19 Vaccine Mfg
  6. COVID-19 Vaccine Status
  7. COVID-19 Vaccine Type

Sage HRMS HR Actions

Processes like the COVID Summary Custom Details Page, which allows you to automatically populate a summary of an employee’s status and results, can only be completed with HR Actions integrated with your Sage HRMS software. However, most of the core features of this customization are still possible through the other Custom Detail Pages.

COVID-19 Vaccination Booster Shot Tracking

Although booster shots are not required to be tracked under the OSHA vaccine mandate (yet), the Delphia plugin does include this functionality. If and when boosters do become a requirement for tracking, you will only need to add the UDF code.

Sage HRMS, Sage 100, SWK Technologies & Delphia Consulting

SWK’s human capital management (HCM) strategy team partners closely with Delphia consulting to deliver proactive guidance and service for our Sage software customers. This partnership allows us to support Sage 100 users as they implement and integrate Sage HRMS with their ERP to build a unified technology stack for their accounting, manufacturing, distribution, HR and payroll processes.

Learn More About the Sage HRMS Plugin for the COVID-19 ETS

OSHA’s Vaccination and Testing ETS is a complex mandate that introduces a lot of new regulation, but the custom ATS for Sage HRMS takes much of the pain away from having to track such a large volume of records for compliance, and can even help those businesses who decide to implement their own processes for keeping their employees safe from COVID-19. To learn more about the vaccine mandate and how this customization helps you address it, watch our on-demand webinar below.

Watch the webinar here and discover exactly how the Sage HRMS plugin solves compliance for the OSHA vaccine mandate.

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