As states across the US expand COVID-19 vaccine eligibility, employers are well-positioned to facilitate vaccine access and improve distribution efficiency. One critical way for employers to achieve these goals is through the operation of workplace vaccination sites, sometimes called closed points of dispensing (CPODs).

On March 16, 2021, the Centers for Disease Control and Prevention (CDC) issued updated guidance on workplace vaccination programs. Among other recommendations, the CDC encourages some employers to implement workplace COVID-19 vaccination sites and outlines best practices for doing so.

According to the CDC, employers with (1) a large number of workers on predictable schedules, (2) the ability to enroll as a vaccination provider or engage an already enrolled vaccination provider, and (3) enough space to operate a vaccination clinic that allows for social distancing should consider operating an on-site vaccination program. Conversely, the CDC recommends an off-site vaccination program for small- or medium-sized employers with a mobile workforce on variable schedules.

The CDC provides several options for employers that choose to operate an on-site vaccination program, including existing occupational health clinics, employer-run temporary vaccination clinics, and mobile vaccination clinics brought to the workplace. Regardless of the model, the CDC advises employers to contact their local health department for guidance. Many jurisdictions have already embraced the CPOD model (e.g. Chicago, IL) and provide extensive information on their websites.

The updated CDC guidance makes clear workplace vaccination clinics should [...]

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