Since President Biden announced his “Path Out of the Pandemic” COVID-19 Action Plan on September 9, 2021 (see our prior post here), an increasing number of employers across the country have implemented, or are in the process of implementing, mandatory COVID-19 vaccination policies. Although these policies may differ in certain respects from employer to employer, they all include (indeed, must include) an opportunity for employees to request an accommodation from any vaccination requirement based on medical/disability grounds, or due to sincerely held religious beliefs.
As these policies have gone into effect, employers have confronted a slew of questions concerning the legal requirements, processes, and nuances of offering religious-based accommodations. In response to this outpouring of uncertainty, on October 25, 2021, the U.S. Equal Employment Opportunity Commission (“EEOC”) updated its Technical Assistance guidance to provide employers with answers to some of the most frequently asked questions concerning when they are required to accommodate (i.e., exempt) employees from mandatory COVID-19 vaccination requirements due to religious reasons under Title VII of the Civil Rights Act of 1964 (“Title VII”). Continue Reading