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Key Points: Vaccinations for COVID-19 are picking up steam around the country as supply increases and eligibility expands. Now is the time for employers to think through issues raised by employee vaccination policies and programs. We address key questions about mandatory and voluntary policies, including discrimination, wage and hour, collective bargaining, safety, privacy and general liability considerations, and offer recommendations for employee vaccination programs. One year into the pandemic, the U.S. Food and Drug Administration (FDA) has issued three Emergency Use Authorizations (EUAs) for COVID-19 vaccines, with more vaccines in various stages of testing. The vaccines are shown to be effective at protecting

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