COVID-19 Vaccination Mandates for School and Work Are Sound

Karen Mulligan, PhD

Jeﬀrey E. Harris, PhD

COVID- Vaccination

Mandates for School and

Work Are Sound Public Policy



COVID-19 Vaccination Mandates for School and Work Are Sound Public Policy

AUTHOR AFFILIATIONS

Karen Mulligan is a Fellow at the USC Schaeffer Center and a Research

Assistant Professor at the USC Price School of Public Policy.

Jeffrey E. Harris MD PhD is a physician at Eisner Health, a federally

qualified community health center in Los Angeles. He is also Professor of

Economics Emeritus at the Massachusetts Institute of Technology

July 1

Support for this white paper was provided by the USC Leonard D. Schaeffer Center for Health

Policy & Economics. The USC Schaeffer Center is funded through the support of the foundations,

corporations, government agencies, individuals, the University of Southern California and our

endowment. A list of donors can be found in our annual reports published online here. The views

expressed in this research are those of the authors, and do not represent the views of the funders.

The Schaeffer Center White Paper Series is published by the Leonard D. Schaeffer Center for

Health Policy & Economics at the University of Southern California. Papers published in this series

undergo a rigorous peer review process, led by the Director of Quality Assurance at the USC

Schaeffer Center. This process includes external review by at least two scholars not affiliated

with the Center.



ABSTRACT

KEY TAKEAWAYS

• Vaccine mandates for employees are emerging as the most feasible and effective

policy to reduce the risk of disastrous COVID- outbreaks in the workplace.

• Higher education and healthcare are leading the way in vaccine mandates, while

other sectors are beginning to follow their lead.

• State laws barring vaccine mandates will become increasingly unenforceable as they

come into conflict with private employer initiatives to protect workers and consumers.

• Concerns that verification of vaccination status is unworkable or that the Food and

Drug Administration has approved COVID- vaccines only on an emergency basis

will prove to be overblown.

• While a clearly articulated, unified federal policy on vaccine mandates remains lacking,

independent agencies such as the Equal Employment Opportunity Commission, the

Occupational Safety and Health Administration, and the Centers for Disease Control

have already begun to step into the void.

In the absence of clearly articulated federal and state policies, private employers have had

to adopt their own vaccination policies to reduce the risk of a disastrous COVID-19 outbreak

among returning workers. Higher education and healthcare have led the way in establishing

vaccination mandates for students and employees, and there are strong indications that

other sectors will follow suit. This trend is reinforced by the emergence of markets for

vaccination-only services, as well as market-based approaches to vaccination verification.

While workplace vaccine mandates have already proved feasible and effective, the alternative

of mixing unmasked vaccinated with masked unvaccinated workers remains untested. State

laws that prohibit vaccination mandates will prove unenforceable as they increasingly

conflict with the policies of large private employers. Vaccine mandates are not only

inevitable, but they are sound public policy. The federal government can play an important

role in endorsing workplace mandates while protecting the most vulnerable and reducing

disparities in disease burden.



Leonard D. Schaeffer Center for Health Policy & Economics

INTRODUCTION

The worldwide COVID-19 epidemic will not be contained

in the near future. Increasingly contagious variants of SARS-

CoV-2 are already prevalent throughout the United States,

and still other potent variants will continue to emerge.

1-3

Even

though two-thirds of the U.S. adult population has received

at least one vaccine dose, vaccination rates remain highly

variable across and within states.

4-6

Cumulative vaccination

rates will continue to level off as the supply of vaccines begins

to surpass remaining demand.

After declining precipitously,

the incidence of new COVID-19 cases has now plateaued

and even increased in some states.

The risks for unvaccinated

people appear to be increasing,

and new outbreaks continue

to be reported.

10, 11

Under these conditions, the foreseeable risk of an outbreak

at a college campus with in-person learning or a worksite

with on-site employees remains ever-present and substantial.

Such an outbreak would prove disastrous for an educational

institution or a business firm, and could have significant

negative spillover effects on surrounding communities.

When

it comes to hospitals, clinics, long-term-care facilities and

other healthcare providers, the risk that an infected employee,

patient or visitor could in turn cause an outbreak among

vulnerable patients is simply too great to bear.

Workplace and college vaccination policies can play an

important role in reducing the risks of future outbreaks. While

some federal agencies have recently issued their own guidelines

on employee vaccinations, the Biden administration has yet to

adopt a unified position and, in fact, has announced that it will

not track vaccinations at the federal level or require a uniform

vaccination credential.

Nor have state governments readily

stepped in to fill the void. This vacuum in clearly articulated

federal and state policies has left college and university

presidents, healthcare administrators, company CEOs and

small business owners with an enormous economic incentive to

create their own mechanisms to prevent outbreaks. At present,

private-sector workplace policies range from strict vaccination

mandates to mask requirements and other safety precautions

for unvaccinated employees. As we see it, the economic forces

of supply and demand increasingly point to vaccine mandates

as the dominant — and, in fact, the preferred — workplace

policy option.

HIGHER EDUCATION AND HEALTHCARE LEAD

THE WAY FOR VACCINE MANDATES

The trend in vaccine mandates among colleges and universities,

healthcare providers and private employers is already unmistakable.

The Chronicle of Higher Education has thus far identified over

500 campuses nationwide that will require vaccination by at

least some students or employees.

The list includes Yale,

Harvard,

MI T,

USC,

Duke,

Tulane,

George Mason,

Stanford,

NYU,

Vanderbilt,

and Notre Dame,

to name

but a few. Some, like Caltech

and Georgetown,

have imposed

mandates only on students. Bowdoin College will require

vaccinations for both students and employees, but with additional

religious exemptions for employees.

The American College

Health Association has recommended COVID-19 vaccination

requirements for all on-campus college students this fall.

Large healthcare systems have likewise begun to impose

similar requirements for employees. At Houston Methodist,

employees who failed to comply have been threatened with

suspension and termination,

30, 31

and one hospital executive

was in fact terminated.

While some employees protested and

even filed an unsuccessful lawsuit,

33, 34

Houston Methodist’s

mandate has proved highly effective. Out of more than 25,000

employees, 96.9 percent have been fully vaccinated, 2.4 percent

have received a medical or religious exemption or a deferral for

pregnancy, and only 0.7 percent have refused vaccination and

were suspended. Of those suspended, more than a few have

already received their first vaccine dose.

Nor is Houston Methodist alone. Penn Medicine,

the largest

private employer in Philadelphia, RWJ Barnabas healthcare

system, operating in nine New Jersey counties, and New York-

Presbyterian hospital system, with 48,000 employees,

have

likewise instituted employee vaccine mandates.

Member

hospitals of the District of Columbia Hospital Association

and the Maryland Hospital Association

have similarly called

for mandatory employee vaccination. Mass General Brigham

will require all of its 80,000 employees to be vaccinated once

the Food and Drug Administration (FDA) fully approves one

of the three vaccines currently approved under emergency

use authorization.

Quite apart from the protests at Houston Methodist,

evidence shows that some healthcare workers may oppose

vaccine mandates at their workplace. A survey in the field

in late February and early March reported that roughly 40

percent of all healthcare workers remained unvaccinated.

And

while a June survey found that only 4 percent of practicing

physicians had been not been fully vaccinated, vaccination rates

among hospital employees are still highly variable.

43, 44

Still,

the drive to achieve near universal vaccination will come from

healthcare management, which has an overwhelming interest

in protecting patients and instilling confidence on the part of

their families.

These decisions by educational and healthcare institutions

serve as a guidepost for the remainder of the private economy.

But they are also sound, well-established policy choices.

Precedent already exists for mandatory vaccinations against



other infectious diseases in some settings. Many states already

have flu-shot requirements for hospital employees.

Meningitis

and hepatitis B vaccination are already required for at least

some university students.

46, 47

THE GROWING IMPETUS FOR EMPLOYEE

MANDATES WILL COME FROM MANAGEMENT

Requirements for employees to be vaccinated or show proof

of vaccination are gradually gathering momentum in other

sectors. In the airline industry, Delta Air Lines has required

new hires to be vaccinated.

In the financial sector, Morgan

Stanley will bar unvaccinated employees and clients from its

New York office,

while Goldman Sachs recently sent out a

memo informing employees that they must promptly report

their vaccination status.

In a recent survey of 1,339 company

facilities in 24 industries conducted in March 2021 as part

of the Arizona State University Workplace Commons, 88

percent of employers planned to require or encourage their

employees to be vaccinated against COVID-19, of whom 60

percent said they will require employees to demonstrate proof

of vaccination.

While one recent survey found that only a

bare majority of Americans supported proof of vaccination as

a requirement for returning to work,

the growing impetus for

employee mandates will once again come from management.

The momentum for vaccine mandates is likewise growing in

the public sector, particularly in municipal governments. San

Francisco will require its employees to be vaccinated once the

FDA grants full approval to currently authorized vaccines.

After the Los Angeles Times reported that only about half of

the city’s police officers and firefighters were vaccinated,

the

Police Commission asked the LAPD to report back on the

feasibility and legality of a vaccine mandate for officers and

alternative work assignments for unvaccinated personnel.

INDEPENDENT FEDERAL AGENCIES

ARE STEPPING IN

While some federal agencies have issued only guidelines

rather than promulgated strict rules, they have nonetheless set

new standards that are already being followed by the private

sector. The U.S Equal Employment Opportunity Commission

(EEOC), in particular, has acknowledged that employers

can require employees to be vaccinated subject to reasonable

accommodations for medical contraindications or sincerely

held religious beliefs.

The U.S. Centers for Disease Control and Prevention (CDC)

has issued numerous guidelines for workplaces and businesses,

including specific industries such as restaurants and bars, food

services, and transportation. Taking a cue from the CDC, the

administration’s Safer Federal Workforce advisory committee

recently noted, “When an employee or contractor voluntarily

discloses that they are unvaccinated or declines to provide

vaccination information, agencies should use that information

to implement CDC-recommended mitigation measures,

including masking and physical distancing.”

Following the

same tack, a joint memo from the Office of Management and

Budget, the Office of Personnel Management, and General

Services Administration has added, “Agencies may establish

occupancy limits for specific workplaces as a means of ensuring

physical distancing between unvaccinated individuals.”

The Occupational Safety and Health Administration

(OSHA) recently issued an emergency temporary standard for

healthcare facilities.

59, 60

Under the standard, fully vaccinated

healthcare workers will not be required to wear masks or

practice social distancing. While the rule at present applies

narrowly to healthcare facilities, it is anticipated that the

U.S. Department of Labor, which has jurisdiction over

OSHA, will issue updated guidelines for other facilities

with an increased risk of transmission, such as meat-

packing plants, correctional institutions, grocery stores and

high-volume retail locations.

The acting head of OSHA

has clarified that the agency will still exercise its power through

its so-called general duty clause to enforce protections for

workers in other industries.

The agency has issued an

additional guidance that removes enforcement of adverse

reaction reporting for required COVID-19 vaccines to

avoid discouraging employees from being vaccinated or

disincentivizing employers’ vaccination efforts.

63, 64

SOME FIRMS HAVE ADOPTED

ALTERNATIVE POLICIES

Responding to these agency guidelines, some companies have

adopted alternative solutions that permit employees to remain

unvaccinated so long as they adhere to restrictions aimed at

reducing the risk of outbreaks.

Amazon, for example, has removed mask requirements

at their warehouses only for vaccinated employees. The

company will enforce the policy through monitoring employee

vaccination status on an internal portal.

Walmart will

likewise allow vaccinated employees to go without masks, and

has offered $75 to field associates to get vaccinated.

Target

and Costco will no longer require face masks for vaccinated

customers as well as employees.

67, 68

In principle, these alternative policies may prove adequate

to ensure workplace safety. Controlling the risk of an outbreak

does not necessarily require that 100 percent of employees

be vaccinated. And it is possible that these alternative

workplace policies will ultimately provide a strong incentive

for unvaccinated employees to get vaccinated. Still, in practice,

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Leonard D. Schaeffer Center for Health Policy & Economics

these alternative policies remain untested. We do not have

evidence on the stability of mixed teams of masked unvaccinated

and unmasked vaccinated workers. Unless all employees are

required to offer proof of vaccination status, we do not know

whether workers will feel confident about their coworkers’

self-reports. As data on the relative effectiveness of workplace

mandates and alternative policies evolve, organizations can

shift their policies. And workers can switch jobs if their

preferred COVID workplace policy does not align with that of

their current employer.

Whether an employer adopts a vaccination mandate or

an alternative policy that allows some employees to remain

unvaccinated, employers will need to reduce the barriers to

getting vaccinated. That means offering paid time off for

employees to get vaccinated and, if needed, paid sick leave for

side effects following vaccination. To that end, Amazon has

already launched on-site COVID-19 vaccination clinics in

several of its warehouses.

MARKET DEMAND IS EMERGING FOR

VACCINATION-ONLY SERVICES

At present, the degree of support for vaccination requirements

for consumers varies considerably with the setting. For example,

support for vaccination requirements to shop in a grocery store

or dine indoors is relatively low (43% and 47%, respectively)

compared with support for requirements to vacation at a hotel,

resort or on a cruise ship (61%) or travel on an airplane (65%).

Current surveys of consumer preferences, however, are static

snapshots that don’t necessarily reveal emerging trends. That

the social media network Tinder has now included vaccination

status as an attribute in one’s dating profile is a harbinger of

things to come.

So is the fact that Evite and Paperless Post

have noted a growing number of hosts requesting that their

guests be vaccinated.

With well over 100 million individuals already vaccinated,

we are already seeing evidence of an emerging market demand

for vaccinated-only sections in sports and entertainment venues

— the LA Dodgers have already gone this route

— as well as

vaccinated-only gyms,

sections of restaurants

and waiting

areas for a wide array of personal services. Bruce Springsteen’s

upcoming concert series in New York City will admit adults

aged 16 or more only if they present proof of having been fully

vaccinated by a vaccine approved by the FDA.

74, 75

Even though a vaccinated person’s overall risk of contracting

COVID-19 is now considered to be low, the inability to

identify others’ vaccination status has left many wary of

resuming such routine activities as in-person grocery shopping

or dining out in restaurants.

This concern may be further

enhanced when their children or other family members remain

unvaccinated or when some family members remain vulnerable

due to chronic illness or immunocompromise. People may have

a strong preference for limiting their activities to businesses

that actively verify vaccination status, or at least enforce mask

wearing and social distancing for their unvaccinated clientele.

The same applies to workers in customer-facing jobs when

they are uncertain of the vaccination status of their clientele.

Nor is there any stopping the emergence of life insurance

policies with discounts for vaccinated individuals. This is

exactly what happened in the case of premium discounts on

life insurance for nonsmokers. In the case of life insurance

for nonsmokers, political efforts to restrict this form of price

discrimination met the unstoppable force of market demand.

And although we do not know the relative risk to mortality of

being unvaccinated compared with smoking, the same has the

potential to happen with insurance policies for the vaccinated.

VERIFICATION OF VACCINATION STATUS IS NOT

A SERIOUS OBSTACLE

Vaccination status, it might be contended, is not readily

verifiable. Age requirements to purchase alcoholic beverages

require a state-issued ID that uses advanced technology to

screen out forgeries. And state governments, in turn, may

have no political appetite for entering into the vaccination

verification business.

These arguments overstate their case. Fulfilment of

immunization requirements for school and work are already

being certified by healthcare providers in the private sector.

Some states have created vaccination databases, which allow

individuals to verify their vaccination status.

Individuals

vaccinated at CVS or Walgreens can obtain proof of vaccination

through their apps or online.

There will be a strong incentive

for private entry into the vaccination verification market, just

as there are private firms currently verifying credit scores. Work

in this area is already being undertaken by the MIT Media

Lab,

IBM

and other private firms.

CONTRARY STATE LAWS WILL LIKELY

FADE AWAY

Legislation barring vaccine mandates has been signed by state

governors in Alabama,

82, 83

Arkansas,

Florida,

85, 86

Texas

87, 88

and Montana.

Similar executive orders have been signed

by governors in several states, including Georgia,

Idaho,

Arizona

92, 93

and Florida.

Comparable legislation has been

filed in most other state legislatures.

In some instances,

the cited rationale is the prevention of discrimination against

the unvaccinated.

This panoply of state-based interventions may appear to

create the impression of enormous ongoing resistance.

But



these initiatives will likely fade under the pressure of the forces

of market supply and demand. Governors and state legislatures

may be able to temporarily retard the implementation of

vaccine mandates in state and local governmental agencies

and public universities. But in the long run, they will likely

not want to interfere with large, powerful employers in the

private sector.

Indeed, most of the state-based actions to date shy away

from confrontation with the private sector. The executive orders

in Idaho and Georgia are restricted only to state agencies,

90, 91

and Arizona’s orders bar only state and local governments and

public universities from imposing vaccination requirements.

92, 93

Others, including Arkansas,

Georgia

98, 99

and Montana

100

not place restrictions on mandates by certain businesses such

as universities, state-owned medical facilities or healthcare,

assisted living and long-term-care facilities. In Ohio, the

Senate blocked a House-passed bill that would have banned

vaccine mandates by private employers, and Gov. DeWine

has said he opposes legislation that discourages vaccination

or prevents businesses from keeping their employees safe.

101

Executive orders in Florida and Texas extend beyond state

and local governments to ban private business from requiring

vaccination documentation for customers, but they do not

restrict vaccine mandates for students and employees by

private institutions.

94, 102

Georgia is a case in point.

Gov. Kemp’s executive order

does not bar Atlanta-based Delta Air Lines from proceeding

with vaccination requirements for its new hires.

Neither

does the order bar Emory University from requiring student

vaccinations.

Nor does it prohibit vaccine mandates for

students, faculty and staff at Clark Atlanta University,

Morehouse College, Morehouse School of Medicine and

Spelman College — the four schools comprising the Atlanta

University Center, home to the city’s historically Black colleges

and universities.

The recent experience of the private cruise industry shows

how state legislation is already conflicting with private-sector

policies. It remains unclear how the new Texas law will apply to

the decision of Carnival Cruise Line to require guests to be fully

vaccinated when it opens operations at the Port of Galveston

on July 3.

103

Norwegian Cruise Lines, which has a mandatory

vaccination requirement for all guests and crew members,

104

has threatened to keep its ships out of Florida ports.

105

Royal

Caribbean Group, by complying with a CDC order that 98%

of crew members and 95% of passengers be vaccinated, was

able to proceed directly to a revenue-generating cruise docking

at a Florida port rather than having to conduct required test

runs.

106

In a lawsuit filed by Florida Gov. DeSantis — and

not by the cruise operators — a federal court recently issued a

preliminary injunction against the enforcement of the CDC’s

order.

107

But the lawsuit does not address the fundamental fact

that the battered cruise industry itself has a strong incentive

to require passengers and crew to be vaccinated. Not only

does the cruise industry want to avoid an onboard outbreak,

but any non-vaccinated passengers it accepts will be unable to

disembark in certain countries, such as St. Maarten.

108

The fact

that the two asymptomatic cases recently detected by Royal

Caribbean Group’s Celebrity Millennium did not result in

an outbreak supports the effectiveness of the cruise operator’s

policy of requiring that all guests and crew be vaccinated.

109

THE ARGUMENT ABOUT EMERGENCY USE

AUTHORIZATION IS A RED HERRING

To date, objections relying on the U.S. Food & Drug

Administration’s (FDA’s) emergency use authorization of

COVID-19 vaccines

110

have not gained legal traction, and

one federal court has already thrown out the argument that

the vaccines are still experimental.

As the court commented,

employees subject to mandates “are not participants in a

human trial.” Whether the contention might sway another

court is likely to be irrelevant over the long run. Both Pfizer

and Moderna are currently seeking full FDA approval, with a

possible decision occurring in summer 2021.

111

The vaccines

now approved on an emergency basis have proved so effective

in the real world, and so lacking in frequent, serious side

effects, that they will more than likely be permanently

approved by the FDA.

112

DON’T IGNORE THE LESSONS OF HISTORY

The concern that some states will represent an immovable

force against vaccine mandates ignores not only economics,

but also the lessons of history. At the turn of the 20th century,

while smallpox was ravaging the U.S., vaccine production

was unregulated and vaccines were of variable quality. Anti-

vax leagues abounded. A black market in forged vaccination

certificates existed, and some doctors signed medical exception

forms for a price. Yet that did not stop the unstoppable tide of

public and private institutions requiring people to display their

scars to gain entry to school, work and other venues.

113

FURTHER FEDERAL AGENCY ACTIONS CAN

REINFORCE PRIVATE VACCINATION POLICIES

It is not hard to imagine other federal agencies stepping into

their respective jurisdictions. Let’s start with the Federal

Aviation Administration (FAA), which has so far issued only

preliminary guidance on airline crew safety.

114

In response

to growing market demand and overwhelming scientific

evidence,

115

in 1972 the FAA (along with the now dismantled

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Leonard D. Schaeffer Center for Health Policy & Economics

Civil Aeronautics Board) first instituted nonsmoking sections

on commercial flights, later banned smoking on flights of

less than two hours, and eventually banned smoking

altogether.

116, 117

But even before then, United Airlines took the

unilateral step of creating a nonsmoking section in 1971.

118

If the

history of the U.S. commercial airline industry’s earlier

accommodation to the evidence on another externality teaches

us anything, we can soon anticipate incremental efforts by

individual airlines and other transportation providers to protect

their passengers and employees. Now that the European Union

will admit vaccinated travelers,

119

vaccination requirements to

board certain international commercial airflights are on the

way as well.

The Advisory Committee on Immunization Practices (ACIP)

has played an important role in developing recommendations

for COVID-19 vaccine use.

120

On the basis of transmission

in healthcare settings, ACIP recommends vaccination or

proof of immunization for Hepatitis B, influenza, measles,

mumps, rubella, pertussis and varicella among healthcare

personnel.

121

An update to existing ACIP recommendations

that incorporates COVID-19 vaccines may provide the

necessary nudge to encourage all healthcare providers to

implement vaccine mandates.

The EEOC’s guidance on workplace vaccinations ensures

employer mandates are not discriminatory and effectively

preempts state laws aimed at stopping vaccination mandates.

Yet the EEOC does not have jurisdiction over workplace safety

and health, both of which will be impacted by COVID-19

vaccination mandates or other policies. Future standards from

OSHA would cover the domain of workplace health and safety

as well as effectively upend all state laws and gubernatorial

edicts. An employer who failed to adhere to an OSHA

standard would not only be subject to inspection and fines,

but would also be liable for negligence in the event of a

workplace outbreak.

While standards imposed by private professional

organizations would not have the same legal effect as actions

by federal agencies, they would still help define what is

considered due care on the part of employers. That is how the

recommendations of the American College Health Association

have influenced college and university decisions,

and how

standards set by professional medical associations would

influence the decisions of healthcare organizations.

EVEN WITH EXEMPTIONS, VACCINE MANDATES

WILL PROVIDE STRONG INCENTIVES

Numerous psychological profiles of vaccine-hesitant individuals

have recently been proposed. According to one analysis, vaccine

hesitancy is deeply ingrained in some people because of their

distrust of the medical establishment or authority in general,

122

core beliefs about personal freedom or the inviolability of

the body, or a hardened sense of fatalism.

123

Another analysis

classifies the vaccine hesitant into the watchful, the cost-

anxious, the system distrusters and the skeptics.

124

Others

have not been vaccinated but for reasons other than hesitancy,

including poor access to transportation, lack of knowledge

about where to get vaccinated or concerns about missing work

due to vaccine side effects.

125

Whatever the classification, resistance to behavioral change

lies along a continuum. The critical issue is what incentives

will effect behavioral change. The prospect of not being able to

return to school or to work, not being able to travel or of being

barred access to a range of social benefits is likely to provide

sufficient incentive to overcome this resistance. The recent

experience of Houston Methodist, where a vaccine mandate

has resulted in at least 97 percent employee compliance, is

prima facie evidence in favor of this proposition.

30, 31

School-

entry vaccination mandates in the U.S. — all of which allow

for varying degrees of exemptions — have been effective at

increasing vaccine uptake.

126

Moreover, states that impose

restrictions on the type of exemption (i.e., only allow medical

exemptions) or make exemptions more difficult to obtain

have lower rates of exemptions.

127

While a meta-analysis of

studies of flu vaccine mandates among healthcare workers

demonstrated a significant effect,

128

the potential consequences

of remaining unvaccinated in the case of COVID-19 are

far greater.

GOVERNMENTS NEED TO ENCOURAGE

VACCINE MANDATES

The evidence reviewed here points to workplace-based vaccine

mandates as a likely consequence of the forces of market

supply and demand, particularly in certain settings such as

healthcare or other essential jobs that require in-person work.

But workplace vaccine mandates are also sound public policy.

Rather than adopting a hands-off, wait-see, neutral approach

to the growing wave of workplace mandates, federal, state and

local governments need to take measures that would promote

and ensure their implementation. Policymakers at all levels can

offer grants and other assistance to educational institutions

and employers to operationalize vaccine requirements. Federal

policy makers, in particular, can work with states and private

companies to develop a national system of verifiable proof

of vaccination that protects the security of personal health

information. Our initial federal vaccine rollout policy of “leave

it to the states” wasted valuable time. Do we really want to

repeat such a piecemeal disaster in our system of verifying

vaccination status?



As we’ve already noted, federal agencies such as the FAA,

EEOC, OSHA and the CDC can establish nationwide standards

that can have far-reaching effects on the implementation

of vaccine mandates and the rate of vaccination in the

United States. Policymakers can also help private professional

organizations develop vaccination standards that can have

sweeping effects on the diffusion of vaccination mandates in

school and the workplace.

WE WILL NEED TO ADDRESS MARGINALIZED,

UNVACCINATED POPULATIONS IN ANY CASE

Some may argue that mandatory vaccinations will result in

marginalized, unvaccinated groups without access to the

benefits of school, work, transportation and basic services. We

will have to address the existence of marginalized, unvaccinated

groups no matter what public policies we adopt.

Nothing bars us from continuing to rely upon other public

policies to convince marginalized individuals to get vaccinated.

Nothing about vaccine mandates negates or interferes with

our continuing use of policies based upon the provision of

accurate information from reliable sources, trusted advisors

and respected community members. Nothing interferes with

our continuing to pursue policies that take advantage of the

example that vaccinated physicians set for their patients.

129

the past, mobile vaccination clinics have provided a successful

means of vaccinating individuals in rural or hard-to-reach

areas.

130, 131

Community health centers can continue to be relied

upon to vaccinate the most socially vulnerable.

132

Nothing

about vaccine mandates stops us from further pursuing these

complementary approaches.

CONCLUSION

Policymakers at the federal level have made enormous efforts

to distribute COVID-19 vaccines widely and to encourage

near-universal vaccination. When it comes to facilitating

workplace vaccine mandates and implementing a nationwide

vaccination tracking system, however, federal officials have

effectively left these tasks to the private sector. Colleges and

universities, hospitals and other healthcare institutions, and

large and small private firms, motivated by the desire to bring

employees back to the worksite and avoid disastrous outbreaks,

have stepped in to fill the void.

COVID-19 vaccines provide businesses, universities

and healthcare organizations with a more effective means

of managing risk than the array of draconian mitigation

strategies adopted by default during 2020. Even in the absence

of governmental policies to require universal COVID-19

vaccination, market forces will drive employers to impose

mandates. And market-driven solutions will emerge to reliably

verify vaccination status.

To be sure, leaving vaccine mandates to the private sector

does give employers the flexibility to tailor their policies to

their own workplace-specific transmission risks and employee

preferences. Still, government has an important role to play

in endorsing sound employer policies, protecting at-risk

populations and reducing disparities in disease burden.

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Leonard D. Schaeffer Center for Health Policy & Economics

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Leonard D. Schaeffer Center for Health Policy & Economics

The mission of the Leonard D. Schaeﬀer Center for Health Policy & Economics

is to measurably improve value in health through evidence-based policy

solutions, research excellence, and private and public sector engagement.

A unique collaboration between the Sol Price School of Public Policy at the

University of Southern California (USC) and the USC School of Pharmacy, the

Center brings together health policy experts, pharmacoeconomics researchers

and aﬃliated scholars from across USC and other institutions. The Center’s

work aims to improve the performance of health care markets, increase value

in health care delivery, improve health and reduce disparities, and foster

better pharmaceutical policy and regulation.

Stephanie Hedt

Director of Communications

Schaeﬀer Center for Health Policy & Economics

University of Southern California

hedt@healthpolicy.usc.edu

213.821.4555