On Wednesday, December 16, 2020, the Equal Employment Opportunity Commission (“EEOC”) added a new section to its ongoing list of questions and answers related to COVID-19. The new questions aim to educate employers and employees about how the Americans With Disabilities Act (“ADA”), Title VII’s anti-religious discrimination provisions and the Genetic Information Non-Discrimination Act (“GINA”) apply during this newest phase of the COVID-19 pandemic that has begun with the availability of vaccines. The “guidance” provided by the EEOC in these new Questions & Answers is littered with pitfalls for employers who will be trying to negotiate a return to normal workplace conditions in the next several months as various COVID-19 vaccines are rolled out.

Read our detailed client alert for a summary of the key points.