All federal employees will be required to provide official documentation of their vaccination status to agency officials or else face disciplinary action, according to guidance issued Sept. 16 by the Safer Federal Workforce Task Force on the requirement that all feds receive a COVID-19 vaccine.

That documentation may take the form of a scan or photo of the original vaccine card, medical record, public health immunization record or other official document that describes the type of vaccine, its administration date and the name of the person or organization administering the vaccine.

Feds will have to “certify under penalty of perjury” the information they provide is correct.

Employees who participated in a clinical trial for a COVID-19 vaccine that has not yet received approval from the Food and Drug Administration, such as the Novavax, and who are documented to have received an active dose independently confirmed to be effective are considered fully vaccinated.

These requirements are not just limited to employees working in an agency office. Feds that are on maximum telework will still have to receive and certify their vaccination by the Nov. 22 deadline “because employees working offsite may interact with the public as part of their duties and agencies may need to recall employees who are on maximum telework or working remotely,” according to the guidance.

Feds hired after Nov. 22 will have to be fully vaccinated before their start date, unless the agency has an urgent need to onboard an employee early and before they are fully vaccinated. In that case, the agency head can issue a limited exemption of 60 days for the employee to become fully vaccinated.

The guidance notes “limited circumstances” may arise where an employee is exempt from the vaccine mandate due to a disability or sincerely held religious belief, but does not offer specifics on the metrics used to evaluate such requests. It notes more specifics on such processes will be forthcoming.

“Determining whether an exception is legally required will include consideration of factors such as the basis for the claim; the nature of the employee’s job responsibilities; and the reasonably foreseeable effects on the agency’s operations, including protecting other agency employees and the public from COVID-19,” the guidance states.

“Because such assessments will be fact- and context-dependent, agencies are encouraged to consult their offices of general counsel with questions related to assessing and implementing any such requested accommodations.”

Employees that refuse to get vaccinated will face disciplinary measures, according to the guidance, up to and including removal from government service. These employees will not be placed on administrative leave while the disciplinary procedures are taking place.

Agencies have been encouraged to expediently contact their collective bargaining units to discuss the vaccine mandate, though the guidance notes bargaining on this topic can only address impact and implementation issues not already covered in said guidance. The implementation deadline of Nov. 22 also cannot be changed because of unfinished bargaining by that time.

Jessie Bur covers federal IT and management.

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