Intentional Backdoor mandate. The testing requirement is cost-prohibitive for most businesses, which will force the hand of businesses to implement a mandate with no testing option.
The ETS states that Employers are not responsible for the cost of testing, unless is is negotiated via a CBA, etc.
What I expect to see is Employers forgo testing because of the paperwork requirements and go right to vaccinations (less any approved exemptions).
One interesting point - Independent Contractors are not subject to the RTS.
I would expect that there will be a move to transition some employees to independent contractors.
In the language OSHA used, claims the “vax” is free, so the testing expense SHALL be forced upon the employee and not the employer.