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Thinking Through COVID Vaccine Incentives

There’s a segment of the population that doesn’t believe in the medical advantages of vaccinations.

2019 Gallup survey, for instance, found that 11% of 1,025 American adults actually consider vaccines to be more dangerous than the diseases they’re intended to prevent.


Given the distaste that some have for vaccines in general, it stands to reason that a fair number of individuals have no intention of receiving one of the vaccines now available to help fend off COVID-19. One recent poll sees more than a quarter of U.S. respondents saying they definitely or probably won’t get vaccinated against the coronavirus.

Many of the American employees who do receive COVID vaccinations will do so via their employer-sponsored insurance plans. And, while companies can — with some exceptions — require employees to receive a coronavirus vaccination, most won’t.

That’s according to an ongoing Mercer survey, which finds 78% of more than 350 employers saying their organization has no plans to mandate the vaccine for employees. (Just 13% said their company is considering mandatory vaccinations at this point.)

Still, employee skepticism toward the coronavirus vaccine creates a challenge for employers with designs on providing vaccines for their workforce. The Mercer poll also looks at the likelihood of companies creating rewards to encourage COVID vaccine uptake among employees who are hesitant about being vaccinated.

Many companies remain unsure as to whether they will provide incentives in hopes of motivating this group of workers to get the vaccine, according to Mercer’s data. Roughly 44% of respondents have already decided against it, but a nearly identical number (46%) said their organization is still thinking and talking it through.

Most of these discussions center around the possibility of offering incentives like cash, gift cards and/or paid time off, Mercer finds, with the still-open survey finding nearly half of employers (47%) indicating they will provide employees with additional paid time off to go get the vaccine. 

Companies that do opt to proceed with such vaccination incentives will have a host of factors to weigh, said Wade Symons, leader of Mercer’s regulatory resource group.

“There are different considerations, depending on whether the employer will be involved in the vaccine administration or simply encouraging employees to seek vaccinations in their communities,” said Symons.

Symons points out that the EEOC’s updated guidance clarifies that the administration of a vaccine alone does not constitute a medical examination, but the questions an employee must answer before receiving the vaccine “will almost certainly qualify as a disability-related inquiry under the Americans with Disabilities Act (ADA).”

As such, ADA restrictions would apply, even if the employer has contracted with a third party to deliver the vaccine.

“In connection with an incentive program, that means the incentive likely must be limited in order for it to be considered a ‘voluntary’ program.”

That said, simply encouraging employees to get vaccinated through, say, a pharmacy chain or county health department would not carry ADA implications, said Symons.

“Limits should not apply, since the pre-vaccination medical questions do not tie back to the employer. And, per the EEOC, requiring proof of vaccination is not a medical inquiry under the ADA. Thus, the employer would be free to ask for such proof in order to provide the applicable incentive.”

Companies providing vaccination incentives should also be careful to provide accommodations due to disability or religious objections, he added.

“The obligation to accommodate would only be implicated in situations where an employee is unable to get the vaccine due to a disability or an objection based on a sincere religious belief, and then, only absent undue hardship to the employer.”

When an accommodation is required, the employer would need to consider alternatives to getting the vaccine, such as periodic COVID testing or remote work options, so the employee with the religious- or disability-related objection can still earn the incentive, said Symons.

“As far as ADA limitations on vaccines, we don’t currently have guidance as to what amount of incentive would exceed the threshold to make vaccination ‘involuntary’ for those employers involved with vaccine administration,” he continued.

“Rules which permitted incentives of up to 30% of the employee-only medical plan premium amount were struck down by the courts several years ago and regulations to replace them have yet to be formally proposed.”

For employees without strong feelings one way or the other, incentives might ultimately be “the nudge they need to make the effort to get vaccinated,” said David Zieg, MD, clinical services leader at Mercer.

On the other hand, such rewards could lead some workers to feel the organization is “coercing them into accepting the vaccine, especially if they are experiencing financial challenges and view the money being offered as substantial,” he added.

“The good news is that the majority of the population is willing to get vaccinated, which means that incentives are not targeted to these people and will not change their behavior.”

Then there are employees for whom no amount of encouragement, financial or otherwise, will likely make much difference, said Zeig.

“Widespread disinformation about COVID-19 vaccines has fostered confusion and distrust. It seems unlikely that incentives will affect the behavior of people who are strongly opposed to taking the vaccine.

That said, it remains unclear whether incentives “will meaningfully improve uptake among those who are hesitant rather than opposed,” said Zeig. “Many will wait to be vaccinated until they feel comfortable, which will take time and experience, not money.”

About the Author

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Mark McGraw is the managing editor of Workspan.

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