Vendors Roll Out Tracking Tools to Help HR Comply with OSHA Vaccine Rule

​How best to track and manage vaccination records is the next step for organizations falling under an imminent federal requirement to mandate COVID-19 vaccination or weekly testing—as well as for the growing number of employers deciding to require vaccination irrespective of the upcoming regulation.

Even though it is not yet clear when the federal mandate will take effect for private-sector employers with 100 or more workers, covered employers should prepare now to comply. This preparation includes implementing the technology needed to track and manage vaccination and testing records. [Update: OSHA released the emergency temporary standard on Nov. 4.]

A variety of vendors now offer surveying and tracking solutions and easy-to-read dashboards. Those vendors include some of the biggest players in HR tech, as well as dozens of new entrants to the field.

Enterprise Systems

Vaccination tracking tools that operate via employees' smartphones and an organization's HR information system are being rolled out. Enterprise HR vendors already have systems that allow employees to upload documents, so including proof of vaccination or testing wasn't a big leap.

"All the big HR vendors have some capability with vaccine surveys and tracking, including ADP, Ceridian, Oracle, SAP and Workday," said Sam Grinter, senior principal analyst at Gartner, based in London. "Most of these tools are not too technically sophisticated. In most cases, they have taken a surveying tool and reconfigured it to track vaccine status."

The majority of solutions rely on the honor system, placing the responsibility on workers to provide valid vaccination records. "The technology being used is generally not cross-checking or auditing vaccine documents," Grinter said.

Demand for tracking solutions has been spiking, according to HR tech vendors. The apps and dashboards take the burden off HR to keep track of who's been vaccinated and who needs testing.

"We knew that a vaccine survey would be an important consideration for employers this year," said David Palmieri, division vice president and general manager at ADP. "In July, we added a vaccine question, allowing employers to poll their employees about their vaccination status. More recently, we added a verification capability so employees can upload proof of vaccination and, earlier this month, a COVID-19 testing results option for unvaccinated employees."

Palmieri said there was "some usage" of ADP's return-to-the-workplace tool back in the fall of 2020 when it first launched, but the vaccination tracking feature has driven significant interest and usage. "That is what employers are struggling to manage the most right now," he said.

ADP's app includes sentiment surveys gauging employees' thoughts on vaccination, vaccine status surveys, health attestation and contact-tracing capabilities. It also includes reporting dashboards where employees can be grouped and filtered by location or other criteria for reporting and metrics purposes.

"HR has access to the tool within their ADP system and can follow the trends around the levels of confidence or anxiety about returning to work, and gain data-driven insights related to the vaccination rate of their workforce," Palmieri said. That allows organizations to make more-informed decisions around workforce planning and staffing needs.

For HR, the experience is Web-based, but for employees, it is mobile-use only for now. Employees get notifications on their phones and must log in to the ADP mobile app. They are then asked if and when they were vaccinated. If employees are fully vaccinated, they are then asked to upload an image of their signed CDC vaccination card. If not vaccinated, employees will be asked if they have tested negative for COVID-19. If they have, they will be asked to upload an image of the latest test results.

"Making it mobile is for speed of use—mobile use through the app has been the most common use case so far," Palmieri said. "As we evolve this tool in the future, we will likely have a desktop experience for the employee as well."

ADP also expects to cover booster shots in the future. Approximately 2.6 million sentiment surveys have been completed on ADP's app, and in the last few weeks, hundreds of thousands of workers have registered vaccination responses.

New Entrants

Dozens of startups have also recently introduced vaccination tracking.

"There are several smaller vendors getting into the space, from several different parts of the world, to meet specific national needs," Grinter said. "We will probably see more since the Biden administration announcement."

Grinter said ReturnSafe is becoming one of the most well-known of the newer vendors offering a tracking solution. "Since Biden's vaccine mandate announcement, ReturnSafe has seen a 141 percent increase in inbound inquiries, the majority from companies with over 1,000 employees," said ReturnSafe CEO Jikku Venkat.

The software manages vaccine-status tracking, testing results, health screenings, case management for employees who test positive for the virus and contact tracing to alert colleagues who may have been exposed. The technology can also be integrated with building access systems so only employees cleared by HR are able to enter the building, something that any employer with an access control system can do if workers use credentials at kiosks located at points of entry.   

Among numerous vendors offering vaccination tracking and management are OfficeTogether, Preworkscreen and ID.me, which publishes an employee's vaccination status in a digital wallet app after ID.me's document review team has verified the proof of vaccination or negative test result. Employees then consent to share their verified status with their HR department or via an employer portal.

Options for Smaller Employers

Grinter said smaller employers covered by the upcoming OSHA regulation may choose to get by with Excel spreadsheets or other manual systems, as most of the vendors who cover the small to midsize business market have not adequately addressed the need for vaccine management.   

Rochester, N.Y.-based Paychex, however, just announced a way to help employers track vaccination status. Through Paychex Flex, employers can send notifications to workers asking them to upload documentation to confirm their vaccination status. Immunized employees can upload a digital copy of their vaccination card, while unvaccinated employees can upload ongoing COVID-19 test results. HR can access both.

Legal Concerns

Vaccine tracking is permissible under federal law regardless of whether your vaccine policy is mandatory or voluntary—and apps can be used to track vaccination status, said Kenneth Broodo, a partner in the Dallas office of Foley & Lardner.

Vaccine status information should be treated confidentially and separately filed, like any other employee medical record, he said. "The best apps will allow for employers to access vaccine and test status while maintaining the information in separate, secure electronic files."

He added that questioning employees about vaccination decisions is OK only in a limited context—accommodation of disabilities and religious observance.