Q: Will employees need a booster shot to count as vaccinated?

A: This is a question that has no answer — at least not right now. "I think we're still in the no man's land in terms of if this will be a requirement," said Steve Bell, a partner at Dorsey & Whitney LLP. 

On Sept. 22, the Food and Drug Administration approved a third dose of Pfizer and BioNTech's coronavirus vaccine for older adults and people at high risk of severe COVID-19. The authorization does not cover individuals who received vaccines developed by Moderna or Johnson & Johnson, according to reporting by HR Dive sister publication Biopharma Dive.

The Centers for Disease Control and Prevention, for now, has not made booster shots a component of someone's status as "fully vaccinated," according to a White House press briefing. 

"Until that happens, it's probably going to be up to the employers to decide whether they feel it's important for the workforce to be vaccinated — booster included," Bell told HR Dive. "If the CDC does say it's necessary, I expect that the feds will adopt that approach."

As employers await additional guidance from the CDC, many may be anticipating information on boosters for other vaccines. Moderna also has started the process of obtaining FDA approval for its booster shot. Meanwhile, health officials have said Johnson & Johnson needs to supply more data before a decision can be made about a potential booster shot.

Employers could elect to include a potential requirement for boosters in their policies, but Bell advised against that. "If it were me, I think I would wait on the CDC," he said. "Sometimes we get ahead of ourselves anticipating, when those eventualities don't ever occur. We create a lot of concern and unnecessary fretting. I think I'd be holding back — we already have enough angst about current vaccinations without anticipating future ones."