Press Release

White House Announces January 4 Deadline for OSHA Rule Mandating COVID-19 Vaccination, Testing for Large Employers

Additional CMS Rule Affecting 17 Million Health Care Workers Does Not Allow Testing Alternative

  • Employers with 100+ employees face the daunting challenge of implementing weekly diagnostic testing or proving vaccination status by January 4, 2022.
  • Each violation of the OSHA rule comes with a fine up to $14,000.
  • CastleBranch’s Diagnostic Test Tracking paired with, provides an essential tool kit to track diagnostic test results, prove vaccination status, and create a secure audit trail to help protect organizations from liability.

November 4, 2021


WILMINGTON, NC—Large businesses with more than 100 employees now have just eight weeks to comply with COVID-19 vaccination and testing mandates or face massive fines. In a November 4 fact sheet, the Biden administration provided details on a January 4 deadline for two rules issued by the Occupational Safety and Health Administration (OSHA) and the Centers for Medicare and Medicaid Services (CMS) which will impact more than 101 million individuals nationwide.


Whereas the OSHA rule allows for weekly diagnostic testing alternatives to vaccination, the CMS rule — covering health care workers at facilities participating in Medicare and Medicaid — does not.


The enormous burden of effectively tracking employee vaccines and weekly diagnostic tests throughout an entire organization falls on internal human resources departments. These HR professionals — the vast majority of whom are not trained in vaccination tracking — will need to successfully collect large amounts of personal data and medical records across their entire staff without accidentally exposing it and violating state and federal data privacy laws. Answers will need to be logged and managed for questions such as:

  • Who received the vaccine?
  • Does each individual have a legitimate proof of vaccination (and not a fraudulent vaccine card)?
  • What was (were) the date(s) and manufacturer(s)?
  • Will the individual need a booster?
  • For those who don’t have the vaccine, are they getting weekly diagnostic testing; what are the results; and how are their results being collected?
  • Does an individual qualify for a religious or medical vaccination exemption?


CastleBranch, a company that released its first COVID-19 solution in April 2020 to help organizations mitigate risk, has identified another stumbling block for these large employers. If the company’s vaccine and diagnostic test tracking process is not carefully documented, creating a secure audit trail, they may be at risk for thousands of dollars in fines per incident in the event of an alleged violation, putting that company’s economic survival in jeopardy.


To help large employers, colleges and universities, CastleBranch created an essential tool kit: Real Vaccination ID and CB COVID-19 Compliance. Included in CB COVID-19 Compliance is the company’s Diagnostic Test Tracking solution, which helps organizations track the results of a diagnostic COVID-19 test via a secure, password–protected platform. The tool helps organizations protect the employee’s private data and information, and also provides a detailed audit trail to help protect the employers from potential liability. The solution can be paired with Real Vaccination ID, which provides digital and physical proof of COVID-19 vaccination status while helping companies create a secure audit trail.


CastleBranch built this essential tool kit with inspiration and guidance from some of the world’s leading epidemiologists and pandemic disease policy experts.


For more information, visit the CB Real Vaccination ID resource page.

Media Contact: Daniel Schechtman, CastleBranch Director of Communications
Phone: 248.761.5084

About CastleBranch:
Located in Wilmington, N.C., CastleBranch is a compliance management and infectious disease screening company serving over 17,700 healthcare programs, tens of millions of individuals, and tens of thousands of employers, schools and healthcare facilities nationwide by verifying identity, tracking over 35 million medical documents, and helping individuals transition to and through professional life. CastleBranch has 20+ years of experience, employs over 500 team members and has a long track record of providing innovative solutions for complex problems.