What to Know About Vaccination Requirements

On Sept. 9, President Biden issued an Executive Order on Requiring Coronavirus Disease 2019 Vaccination for Federal Employees. The President states that immediate action must be taken to protect the federal workforce and individuals interacting with the federal workforce. Therefore, by 22 Nov 21, all direct-hire federal employees must be fully vaccinated, including Exchange associates.

You may have questions about what the Executive Order means for you. The Exchange’s HR team has curated a list of frequently asked questions and responses. The Exchange Post will update this FAQ as needed.

1. Why are Exchange associates required to be fully vaccinated?

A: Executive Order 14043, Section 3b, requires all direct-hire federal employees to be fully vaccinated, including Non-Appropriated Fund Exchange associates.

2. By what date do associates need to be fully vaccinated?

A: Associates must be fully vaccinated by Nov. 22, 2021.

Associates will be considered fully vaccinated for COVID-19 two  weeks after they have received the requisite number of doses of a COVID-19 vaccine approved or authorized for emergency use by the U.S. Food and Drug Administration or that has been listed for emergency use by the World Health Organization. For Pfizer-BioNTech, Moderna, or AstraZeneca/Oxford, that is two weeks after an associate has received the second dose in a two-dose series. For Johnson and Johnson (J&J)/Janssen, that is two weeks after an associate has received a single dose.

3. By what date do associates need to have COVID-19 vaccination?

A: Associates must receive their last dose of their vaccine no later than Nov. 8, 2021, to meet the Nov. 22, 2021, deadline to be fully vaccinated.

The timing between the first and second shots depends on which vaccine is received.

If someone receives the:

• Pfizer-BioNTech COVID-19 vaccine, that person should get their second shot three weeks (or 21 days) after the first. This means for associates to meet the vaccination deadline, they should receive their first vaccination no later than  Oct. 18, 2021. They would not be eligible for the second dose until Nov. 8, which is the deadline to have received both shots.
• Moderna COVID-19 vaccine, that person should get their second shot fourweeks (or 28 days) after their first. This means for associates to meet the vaccination deadline, they should receive their first vaccination no later than Oct. 11, 2021. They would not be eligible for the second dose Nov. 8, which is the deadline to have received both shots.

Because the Johnson & Johnson vaccine only has one shot, associates have until Nov. 8 to receive it and still meet the Nov. 22, 2021, deadline to be fully vaccinated.

Associates are encouraged to plan and allow enough time to receive all required vaccine doses before the Nov. 8 deadline to have their second shot

Date	Action
Oct. 11	First dose deadline for associates receiving the Moderna vaccine
Oct. 18	First dose deadline for associates receiving the Pfizer-BioNTech vaccine
Nov. 8	Deadline for associates receiving the Johnson & Johnson vaccine
Nov. 8	Second dose deadline for Moderna and Pfizer vaccines
Nov. 22	Deadline for all associates to be fully vaccinated

 

4. By what date do applicants hired after Nov. 22, 2021, need to be fully vaccinated?

A: Applicants hired after Nov 22, 2021, need to be fully vaccinated before their start date.

5. Does the requirement to be vaccinated apply to associates who are not reporting to the worksite (e.g., are on maximum telework or working remotely)?

 

A: Yes. To protect the health and safety of the workforce, all associates covered by Executive Order 14043  and without a legally required exception (approved medical and/or religious accommodation) need to be fully vaccinated by Nov. 22, 2021, regardless of where they are working. Associates who are on maximum telework or working remotely are not excused from this requirement.

6. Is the Exchange required to provide onsite vaccinations to associates?

A: No. Given the widespread availability of vaccinations, the Exchange is not required to provide vaccinations at their facilities or HQ.

 

Vaccination Documentation and Information

7. Are associates required to provide documentation to prove their vaccination status?

A: Yes. Associates are required to provide documentation to prove vaccination, even if the associate has attested to their vaccination status. Information on how to provide documentation will be communicated soon.

Associates may provide:

• A copy of the record of immunization from a healthcare provider or pharmacy
• A copy of the COVID-19 Vaccination Record Card
• A copy of medical records documenting the vaccination
• A copy of immunization records from a public health or state immunization information system or
• A copy of any other official documentation containing the required data points.

The required data points that must be on any official documentation submitted are:

• Associate’s name
• The type of vaccine administered
• Date(s) of administration and
• The name of the health care professional(s) or clinic site(s) administering the vaccine(s).

Associates must certify under penalty of perjury that the documentation they are submitting is true and correct.

Associates may provide a digital copy of such records, including, for example, a digital photograph, scanned image, or PDF of such a record that clearly and legibly displays the information outlined above.

8. Will proof of vaccination documentation be reviewed to determine authenticity?

A: Yes. Documentation will be reviewed to ensure the information is authentic. An associate who provides false documentation will be subject to disciplinary action up to and including separation.

 

Limited Exceptions to Vaccination Requirement (Accommodations)

9. Are there exceptions to the requirement for all associates to be fully vaccinated?

A: Associates must be fully vaccinated other than in limited circumstances where the law requires an exception. In particular, the Exchange may be required to provide a reasonable accommodation to associates who communicate to the Exchange that they are not vaccinated against COVID-19 because of a disability or because of a sincerely held religious belief, practice or observance. Determining whether an exception is legally required will include consideration of factors such as the basis for the claim; the nature of the associate’s job responsibilities; and the reasonably foreseeable effects on the Exchange’s operations, including protecting other Exchange associates and the public from COVID-19.

10. What is the process to request medical or religious accommodations?

A: To request a medical or religious exemption please complete Exchange Form 1600-005. Any questions about medical or religious exemptions should be sent to covid-19accom@aafes.com.

11. When should associates submit a request for medical or religious accommodations?

A: Immediately. Associates should submit a request for medical or religious accommodations to the Accommodation Resolution Team (ART) at covid-19@accom@aafes.com by completing Exchange Form 1600-005 as soon as possible.

Enforcement of Vaccination Requirement for Associates

12. What steps may the Exchange take if an associate refuses to be vaccinated or provide proof of vaccination?

A: The Exchange will provide associates with information regarding the benefits of vaccination and ways to obtain the vaccine. If the associate continues to refuse to be vaccinated or provide proof of vaccination, the Exchange will pursue disciplinary measures, up to and including separation from Exchange employment.

13. What happens to an associate that falsifies proof of COVID-19 vaccination?

A: An associate who knowingly and willfully submits false COVID-19 vaccination documentation will be subject to disciplinary action up to and including separation.

 

Safety Protocols Related to Vaccination

14. Who is considered fully vaccinated?

A: People are considered fully vaccinated for COVID-19 two weeks after they have received the second dose in a two-dose series (Pfizer-BioNTech or Moderna), or two weeks after they have received a single-dose vaccine (Johnson and Johnson (J&J)/Janssen). There is currently no post-vaccination time limit on fully vaccinated status.

This guidance applies to COVID-19 vaccines currently either approved or authorized for emergency use by the U.S. Food and Drug Administration (Pfizer-BioNTech, Moderna, and Johnson & Johnson [J&J]/Janssen COVID-19 vaccines). This guidance can also be applied to COVID-19 vaccines that have been listed for emergency use by the World Health Organization (e.g., AstraZeneca/Oxford). More information is available at Interim Clinical Considerations for Use of COVID-19 Vaccines | CDC.

15. Can an associate who participated in a clinical trial for a COVID-19 vaccine be considered fully vaccinated?

A: Clinical trial participants from a U.S. site who are documented to have received the full series of an “active” (not placebo) COVID-19 vaccine candidate, for which vaccine efficacy has been independently confirmed (e.g., by a data and safety monitoring board), can be considered fully vaccinated two weeks after they have completed the vaccine series. Currently, the Novavax COVID-19 vaccine meets these criteria. More information is available here.

16. Is the Exchange required to establish different safety protocols for fully vaccinated and not fully vaccinated individuals?

A: Yes. Fully vaccinated individuals do not need to physically distance or have restrictions on their official travel (although they still must comply with any local requirements and relevant CDC guidance for fully vaccinated individuals while traveling). Fully vaccinated individuals in areas of substantial or high transmission (see the CDC COVID-19 Data Tracker County View) need to wear a mask in public indoor settings. Fully vaccinated individuals in areas of low or moderate transmission do not need to wear a mask, unless required by local installation command.

Fully vaccinated individuals might choose to wear a mask regardless of the level of transmission for a variety of reasons.

Some associates will not be vaccinated because they are legally entitled to a reasonable accommodation.

Associates who are not fully vaccinated must wear masks regardless of community transmission level; physically distance; and comply with travel requirements for not fully vaccinated individuals.

17. Prior to an associate being fully vaccinated, what protocols should that individual follow?

A: Associates who are not fully vaccinated must comply with all Exchange and applicable DoD requirements for individuals who are not fully vaccinated, including those requirements related to masking, physical distancing and travel, subject to any legally required reasonable accommodation.

18. Are contractors affected by the vaccination mandate?

A: Yes. Executive Order 14042 applies to contractors.

 

Additional Questions

19. Why does the military have a different vaccination suspense?

A:  A 24 August 2021 memorandum from the Secretary of Defense advised the Secretaries of the Military Departments to “impose ambitious timelines for implementation” of the vaccination requirement. This memorandum gives each military branch the authority to establish an independent suspense date and issued prior to President Biden’s Executive Order.

20. Are associates who previously tested positive for COVID-19 required to be fully vaccinated?

A: Yes. All associates are required to comply with the vaccination mandate (Executive Order 14043) regardless of whether they previously tested positive for COVID-19. Should an associate have a concern he/she may request a medical exemption by completing Exchange Form 1600-005 and submitting it to covid-19accom@aafes.com.

21. Can an associate who does not want to get vaccinated be granted leave without pay (LWOP) until the requirement is lifted?

A: There is no provision to grant LWOP to an associate that has chosen not to get vaccinated.

22. If an associate is terminated for failing to comply with the vaccination mandate (Executive Order 14043) are they eligible for unemployment?

A: Eligibility for unemployment benefits is determined by the state of residence. The associate will need to contact their state’s unemployment office for additional information.

23. If an associate is terminated for failing to comply with the vaccination mandate (Executive Order 14043) are they eligible for rehire if the requirement is lifted or they are later fully vaccinated?

A: Yes. An associate who is terminated for failing to comply with the vaccination mandate may be eligible for rehire should the associate later meet the requirements of the mandate or if the mandate is rescinded.

 

Administrative Leave for COVID-19 Vaccination

24. Are associates granted duty time off (administrative leave) to receive a COVID-19 vaccination to include the booster (third dose)?

A: Yes. Associates are granted duty time off (up to four hours of administrative leave) per vaccination dose. For example, an associate may be granted up to 12 hours of administrative leave to receive three doses of the COVID-19 vaccination. If, because of unforeseen circumstances, the associate is unable to obtain the vaccine during his/her basic tour of duty hours, the normal overtime hours of work rules apply. If an associate spends less time getting a vaccine, only the required amount of duty time off (administrative leave) should be granted.

25. How do I inform my supervisor that I have an appointment to receive the COVID-19 vaccination?

A: Associates should submit a leave request in advance to their supervisor as they do for all other leave requests (through KRONOS or with the Request for Leave Form 1400-006).

26. What leave option should I select when requesting administrative leave for the COVID-19 vaccination?

A: In KRONOS:

• PB: Select ‘US Mgr Admin – COVID S1’ or ‘US Mgr Admin – COVID S2’, as applicable and type ‘COVID-19 Vaccination – Associate or COVID-19 Vaccination – Family Member’ in the message section.
• Hourly: Select ‘US Admin – COVID S1’ or ‘US Admin – COVID S2’, as applicable and type ‘COVID-19 Vaccination – Associate or COVID-19 Vaccination – Family Member’ in the message section.

       Request for Leave Form 1400-006:

• Check the box for ‘Admin Leave’ and state ‘COVID-19 Vaccination – Associate or COVID-19 Vaccination – Family Member’ as the reason

27. Will associates be able to use administrative leave to take a family member to receive the COVID-19 vaccine?

A: Yes. Associates will be granted up to four hours of administrative leave per vaccination dose to accompany a family member who is receiving the COVID-19 vaccination. For example, an associate may be granted up to 12 hours of administrative leave to accompany a family member receiving three doses. If an associate spends less time accompanying a family member who is receiving the COVID-19 vaccine, only the required amount of administrative leave should be granted.

In accordance with 5 CFR 630.201 a family member means an individual with any of the following relationships to the associate:

1. Spouse, and parents thereof;
2. Sons and daughters, spouses thereof;
3. Parents, and spouses thereof;
4. Brothers and sisters, and spouses thereof;
5. Grandparents and grandchildren, and spouses thereof;
6. Domestic partner and parents thereof, including domestic partners of any individual in paragraphs (b) through (e) of this definition; and
7. Any individual related by blood or affinity whose close association with the associate is the equivalent of a family relationship.

 

28. Where do I go to register/receive the COVID-19 vaccine?

A: Please contact your local health department or click here for information on locations that are administering the COVID-19 vaccination and the registration process.

29. Will I be reimbursed for travel expenses if I must travel to a vaccination site outside of my normal commuting area?

A: No. Associates will not be reimbursed for travel-related expenses while on administrative leave to receive a vaccination dose nor to accompany a family member receiving a vaccination dose.

30. If I become ill or experience an adverse reaction after being vaccinated, will I be granted administrative leave for my recovery period?

A: Yes. Associates who experience an adverse reaction to a COVID-19 vaccination will be granted up to two workdays of administrative leave to recover from a single vaccination dose.

31. What if I experience an adverse reaction to a COVID-19 vaccination dose that requires more than two workdays to recover from?

A: Associates are required to use annual leave or sick leave if he/she requires more than two workdays to recover from an adverse reaction to a COVID-19 vaccination.