To assist in keeping up with the current on status on each mandate, please refer to the summary below. Note that this issue continues to evolve under each of the three separate mandates.
The GBS Compliance will continue to keep you updated. In the meantime, employers who are affected should prepare to comply by the effective dates.
Private Employers with 100+ Employees
Type of Rule
OSHA Emergency Temporary Order
Effective Date
Originally December 5, 2021 and January 4, 2022
Moved to January 10 , 2022 and February 9, 2022
Current Status
Not effective
Federal Court stay in place per the U.S. Supreme Court decision on 1/13/22
Steps / Recommendations for Employers
Employers could continue preparations to comply with the mandate in event stay is lifted or could postpone preparations until the merits of the mandate are decided through the federal court system.
Health Care Workers Employed by Employers who Participate in Medicare / Medicaid Programs Including Providers and Suppliers
Type of Rule
CMS Rule
Effective Date
Originally December 5, 2021
and January 4, 2022
Now January 27, 2022 and February 26, 2022 (for states with no stay)
Now February 14, 2022 and March 15, 2022 (for states with a lifted stay)
Current Status
Effective for all states
There was no federal court stay for certain states but for the remaining states, the U.S. Supreme Court lifted the stay on 1/13/2022
Steps / Recommendations for Employers
Affected employers in all states should prepare in order to meet the current deadlines.
The first date represents the deadline for the first dose, and the second date represents the deadline for the second dose (and the single dose vaccine)
There are technically different (later) effective date for states that were under the stay, these states are: Alabama, Alaska, Arizona, Arkansas, Georgia, Idaho, Indiana, Iowa, Kansas, Kentucky, Louisiana, Mississippi, Missouri, Montana, Nebraska, New Hampshire, North Dakota, Ohio, Oklahoma, South Carolina, South Dakota, Utah, West Virginia and Wyoming.
All Federal Workers and Contractors including all Employees Working on or in Connection with Covered Federal Government Contracts and Subcontracts
Type of Rule
Safer Federal Workforce Taskforce Guidance
Effective Date
Originally December 8
Moved to January 4, 2022
Moved to January 18, 2022
Current Status
Federal Court stay for all states
Steps / Recommendations for Employers
Affected employers should continue preparations to comply with the mandate in event stay is lifted
