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Missouri Emergency Rule Allows Employers to Request Reclassification of Workforce's COVID-19 Vaccine Priority Tier



February 16, 2021

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Labor & Employment 
Legal Updates

On January 14, 2021, the Missouri Department of Health and Senior Services (DHSS) established vaccine priorities for many of the industries within Missouri’s workforce. Until now, employers could not appeal their vaccine priority status. However, on February 9, 2021, the Missouri Secretary of State posted an Emergency Rule which provides an avenue for employers to submit a request to move their organization to a different vaccine priority phase.

This Rule offers definitions and procedures that Missouri’s COVID-19 Vaccine Priority Tier Evaluation Committee and Missouri’s Director of DHSS must follow after an employer submits a request for reclassification. The Rule was designed to ensure Missouri employees receive vaccinations as soon as possible and practical for their occupation.

What does this mean for your workforce?

If you are a Missouri employer and believe your employees should be classified under a COVID-19 vaccine priority tier which they are not currently under, then you may submit a reclassification request to the Committee via Missouri’s online website submission application. (Employers can request forms HERE or by emailing [email protected].) After your request is submitted, the Committee has 10 days to evaluate the request and submit their recommendation to the DHSS Director. Within 5 days, the Director will issue a written decision that either grants or denies your request.

Contact us

If you have questions about your company’s current COVID-19 vaccine priority tier, a request for reclassification or other vaccine-related issues, contact Julianne Story, Courtney Steelman, Natalie Holden or your Husch Blackwell attorney.

CARES Act, COVID-19 & Return-to-Work Guidance

Husch Blackwell provides guidance regarding COVID-19 updates, the CARES Act, and rapidly changing state-by-state orders, including those that impact stay-at-home and return-to-work protocols. Contact these legal teams or your Husch Blackwell attorney to plan a way through and beyond the pandemic.


Courtney Steelman

Senior Associate

Lowell Pearson

Office Managing Partner