Can Our Health Center Mandate the Vaccine and Other Frequently Asked Questions and Answers

Updated 9/10/2021: This document is intended to assist health centers with legal considerations regarding imposing employee vaccine mandates from an operational and policy perspective. This FAQ will be a living document that will be updated as the COVID vaccination landscape evolves. Additional resources (e.g., sample policies) will be available to supplement this document. Note that this is a final draft.

COMING SOON: Stay tuned for date and time for our upcoming national webinar once CMS posts their Interim Rule per the September 09, 2021 announcement on vaccination requirements in health care settings. We’ll walk through the components together and learn from health center leaders around the country who are implementing the vaccine mandate. Contact

Note: This document summarizes current legal parameters and general employment regulations when considering an employee vaccine mandate. This is not a document providing legal coverage or formal opinion and is instead intended to concisely inform the reader on key considerations and applicable guidance. Health centers should consult with local counsel to ensure compliance with state and local public health and employment requirements. This document will be updated by NACHC and FTLF in accordance with emerging conditions related to the COVID-19 pandemic.

Find more COVID-19 resources for health centers

Visit NACHC’s COVID-19 Information and Resources for Community Health Centers to find materials addressing a range of health center concerns related to COVID-19.