If 2020 was a tough year for legal departments, 2021, which started just weeks after health care workers began receiving the first COVID-19 vaccine doses in the country, seemed to promise much-needed relief from the pandemic—and even a semblance of normalcy.

But as the vaccines became increasingly accessible throughout the year, they introduced a whole new set of issues that left in-house counsel as busy as ever. With litigation on key vaccination questions pending and the possibility of more policy changes on the horizon, in-house counsel are going into 2022 with one clear-eyed expectation: There will be more challenges.