On October 25, 2021, the Equal Employment Opportunity Commission (EEOC) expanded its prior guidance “What You Should Know About COVID-19 and the ADA, the Rehabilitation Act, and Other EEO Laws” to include recommendations for employers who receive religious objections from employees in response to the employer’s mandatory COVID-19 vaccination policy. Specifically, the EEOC added section L to its prior guidance, which addresses specific questions relating to religious objections. The newly added questions are set forth below. All employers should review and familiarize themselves with this guidance as they continue to face objections and accommodation requests from employees with respect to COVID-19 vaccine mandates.
According to the EEOC’s guidance, employees must inform their employer they are requesting an exception to a COVID-19 vaccination requirement. Although there are no “magic words” employees must use, they need to inform their employer that there is a conflict between their sincerely held religious belief and the employer’s vaccination requirement.
The EEOC recommends that employers provide employees and applicants with information regarding whom to contact and any procedure to use to request a religious accommodation.
As a best practice, an employer should provide employees and...
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