May 2022

State Updates


Illinois - Chicago adopts vaccination mandate for certain employers


Author: ADP Admin/Tuesday, January 4, 2022/Categories: Compliance Corner , State Compliance Update, Illinois

Chicago has issued a public health order that requires certain employers to verify employees are fully vaccinated against COVID-19. If employees aren’t fully vaccinated, they must wear a mask when interacting with patrons and provide proof of a weekly negative COVID-19 test. The requirements take effect January 3, 2022.

Note: The order also requires covered employers to verify the vaccination status of patrons.

The Details:

Covered Employers:

The public health order applies to the following entities:  

·       Indoor Dining: Establishments where food or beverages are served, including, but not limited to, restaurants, bars, fast food establishments, coffee shops, tasting rooms, cafeterias, food courts, dining areas of grocery stores, breweries, wineries, distilleries, banquet halls, and hotel ballrooms; and 

·       Indoor Fitness: Gyms and fitness venues, including, but not limited to, gyms, recreation facilities, fitness centers, yoga, Pilates, cycling, barre, and dance studios, hotel gyms, boxing and kickboxing gyms, fitness boot camps, and other facilities used for conducting indoor group fitness classes; and 

·       Indoor entertainment and recreation venues where food or beverages are served: Including, but not limited to, movie theaters, music and concert venues, live performance venues, adult entertainment venues, commercial event and party venues, sports arenas, performing arts theaters, bowling alleys, arcades, card rooms, family entertainment centers, play areas, pool and billiard halls, and other recreational game centers.

Requirements for Covered Employers:

All covered employers must:

·       Determine the vaccination status of each employee.

·       Require each vaccinated employee to provide acceptable proof of vaccination status, including whether they are fully or partially vaccinated.

·       Treat any employee who doesn’t provide one of the acceptable forms of proof of vaccination as not fully vaccinated.

Covered employers must ensure that employees who aren’t fully vaccinated and who report at least once every seven days to a workplace where other individuals such as coworkers or customers are present are:

  • Tested for COVID-19 at least once every seven days; and
  • Provide documentation of the most recent COVID-19 test result to the employer no later than the seventh day following the date the employee last provided a test result.

Covered employers must also ensure that employees who aren’t fully vaccinated and don’t report during a period of seven or more days to a workplace where other individuals are present are:

  • Tested for COVID-19 within seven days prior to returning to the workplace; and
  • Provide documentation of that test result upon return to the workplace.

If an employee doesn’t provide documentation of a COVID-19 test result as required, the employer must keep that employee removed from the workplace until they provide a test result.


In addition, when an employee has received a positive COVID-19 test, or has been diagnosed with COVID-19 by a licensed healthcare provider, the employer must remove the employee from the workplace immediately and until they meet criteria for return and may not require that employee to undergo COVID-19 testing for 90 days following the date of their positive test or diagnosis.


Note:  Employees who aren’t fully vaccinated must also wear a face mask when interacting with patrons.


Written Plan Required:


Covered employers must develop and keep a written plan describing the protocol for implementing and enforcing the requirements of the order. The city has created a sample compliance plan that employers may use.




Covered employers must maintain a record and a roster of each employee's vaccination status. Employers must also maintain a record of each test result provided by each employee. This information is subject to applicable legal requirements for confidentiality of medical information. These records must be preserved while the order is in effect.

Next Steps:

If you are a covered employer:

·      Refer to the city’s resources.

·      Develop, implement, and enforce a written compliance plan.

·      Notify employees.

·      Display signs at all entrances.

·      Train supervisors on how to enforce the requirements.

·      Amend written policies if necessary.

Please contact your dedicated service professional with any questions.

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Tags: 01/06/22

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