New OPM Guidance on Vaccination Requirements


Today, OPM released two new guidance memos on the vaccine mandate: one applying the vaccine mandate to new hires and another on enforcement, including FAQs. The Safer Federal Workforce Task Force also released new and updated guidance regarding vaccinations that mirrors the OPM guidance, found here:

NFFE pushed for the Biden Administration to adopt a progressive discipline approach across all of government for fairness and consistency. The guidance sets forth a discipline process that provides multiple chances for compliance and starts with counseling and education about the vaccine. Employees will be given five days to provide the required vaccine documentation or request an exception. If the employee has not demonstrated that they have received at least the first dose of a vaccine by the end of the counseling and education period, the agency will issue discipline. We expect most cases to progress from counseling, to short suspension of fourteen days or less, to removal. OPM also recommends certain guardrails to ensure consistency in penalty assessment, such as designating one management official to propose all discipline in a work unit and another management official to be the deciding official for all disciplinary actions in a work unit. The Douglas Factors will also apply to all discipline. NFFE collective bargaining agreements continue to apply with full force and effect on various aspects of the vaccine mandate.    

Coming soon… The Administration will provide detailed guidance on requesting exemptions and the Reasonable Accommodations process in the coming days. Please continue to send questions concerning the vaccine mandate to your Business Representative, Jeff Friday at and Yvette Piacsek at