Vaccine Policy Separations

President Biden recently announced a vaccine mandate for all employers with 100 or more workers that requires their workers be vaccinated or undergo weekly COVID-19 testing. Employers that don’t comply can face fines up to $14,000 per incident. Businesses across the U.S. are awaiting details in a formal rule that OSHA plans to issue in the coming weeks.

Controlling your unemployment costs and reporting employees who do not comply with your company’s vaccine policy is just one part of the overall vaccine mandate puzzle.  In an effort to make it easier to identify individuals who have quit or have been discharged related to the vaccine policies, Thomas & Company has added new separation codes to document these cases.

  • Voluntary Quit – Refused COVID-19 Vaccination (T&C Separation Code: 71)
  • Discharge – Refused COVID-19 Vaccination (T&C Separation Code: 72)

When can I start using the new separation codes?

The new codes are currently active and available.

How can I begin reporting these cases to T&C?

If you use SHIELD to communicate with your T&C Analyst, simply select the new code from the drop-down menu when responding to the case and provide any documentation.  Strong documentation and uniform enforcement can improve the odds of winning unemployment cases.  Documentation should include:

  • Do you have a formal vaccine policy in place?
  • How were employees made aware of the policy?
  • Do you have a signed acknowledgement that they received and were aware of the policy?

What do I need to do if we provide separation data in a file feed?

If you are providing separation information via a file feed with T&C, you can also modify your file feed to include the new codes. We need to be notified in advance so we can assure that the separations are mapped correctly.  This mapping can typically be completed in 48 hours or less once we are notified of the new data coming over in the feed. Please contact your Client Relationship Manager if you want to send vaccine related separations in your file feed so that these codes can be mapped.


We know that employers have a lot of questions around President Biden’s vaccine mandates, and we are monitoring this situation and will provide any updates as they become available. Thomas & Company is committed to providing up to date guidance and support as we enter the next phase of the COVID-19 pandemic.

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