Federal employees that fail to receive their final dose of a COVID-19 vaccine by Nov. 8 could face disciplinary actions as soon as the next day, according to guidance issued by the Office of Personnel Management Friday.

President Joe Biden’s executive order mandating federal employees receive COVID vaccinations requires feds to be fully vaccinated by Nov. 22.

Full vaccination occurs two weeks after a person receives their final dose of the vaccine, meaning that an employee who has not received their final shot by Nov. 8 will not be fully vaccinated by the deadline.

OPM recommended that agencies use progressive responses to an employee’s refusal to get vaccinated, beginning with counseling and education processes to encourage that employee to change their mind. Feds would have five days under that disciplinary process to either submit documentation of their plans to get vaccinated or submit a request for exemption.

“Agencies are reminded that generally the objective of discipline is to correct deficiencies in employee conduct. Discipline can deter misconduct and correct situations interfering with the efficiency of civil service. While the law and OPM adverse action regulations do not require progressive discipline, this is the preferred approach in the instance of non-compliance with the requirement to be vaccinated. With this in mind, agencies are strongly encouraged to consider whether lesser disciplinary penalties are adequate, as an initial matter, to encourage an employee to be vaccinated, such as a short suspension of 14 days or less,” the guidance states.

“If a short suspension proves inadequate in encouraging an employee to become vaccinated, agencies should then consider a greater disciplinary penalty, such as removal or termination from the federal service.”

OPM encouraged larger agencies to designate one official to propose disciplinary action and one official to decide on disciplinary action so that responses are consistent across similar employees.

Employees can request a medical or religious exemption from the mandate, though agencies will only grant such accommodation requests that are required y law.

“An employee whose request for an accommodation is denied should receive their first (or, if a one-dose series, only) dose within two weeks of the final determination to deny the accommodation,” the guidance states.

The only other employees that are exempt from the deadline are those that are on extended leave – such as parental leave, medical leave or leave from a workplace injury – or those employees that only work seasonally, who must submit proof of full vaccination before their return to government work.

OPM also advised agencies to include vaccine requirements in their job listings and offer letters, notifying potential feds of their responsibility to get fully vaccinated before their start date.

Jessie Bur covers federal IT and management.

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