Department of Veterans Affairs VHA DIRECTIVE 1193.

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Veterans Health Administration Transmittal Sheet
Washington, DC 20420 January 27, 2022

CORONAVIRUS DISEASE 2019 VACCINATION PROGRAM FOR VETERANS

HEALTH ADMINISTRATION HEALTH CARE PERSONNEL

1. REASON FOR ISSUE: To establish policy and provide guidance for mandatory
coronavirus disease 2019 (COVID-19) vaccination for health care personnel (HCP) in
the Veterans Health Administration (VHA), hereafter referred to as VHA HCP. VHA
Directive 1193 was the controlling policy for VHA HCP from August 13, 2021, until
October 3, 2021. From October 4, 2021, until the publication date of this updated policy,
the controlling policy for vaccination for VHA HCP was VA Notice 22-01, which updated
VA Handbook 5019. This policy, VHA Directive 1193.01, reinstates and updates VHA
Directive 1193 that was published on August 13, 2021.

2. SUMMARY OF MAJOR CHANGES:

a. This version updates the submission process for vaccination information.

b. This version updates the information for applicants and vaccination information.

3. RELATED ISSUES: VA Notice 22-01, VHA Directive 1131(5), Management of

Infectious Diseases and Infection Prevention and Control Programs, dated November 7,
2017, and VHA Directive 1192.01, Seasonal Influenza Vaccination Program for VHA
Health Care Personnel, dated August 10, 2020.

4. RESPONSIBLE OFFICE: The Office of Occupational Safety and Health (19HEFB) is

responsible for the contents of this VHA directive. Questions may be referred to the
COVID-19 Resource Room at https://dvagov.sharepoint.com/sites/VHAOHT/SP-
Directory/COVID-19%20Response%20Team/Lists/RR/Item/newifs.aspx. NOTE: This is
an internal VA website that is not available to the public.

5. RESCISSIONS: VHA Notice 2021-18, Supersession and Replacement of VHA

Directive 1193, Coronavirus Disease 2019 Vaccination Program for Veterans Health
Administration Health Care Personnel is rescinded.

6. RECERTIFICATION: This VHA directive is scheduled for recertification on or before

the last working day of January 2027. This VHA directive will continue to serve as
national VHA policy until it is recertified or rescinded.

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January 27, 2022 VHA DIRECTIVE 1193.01

BY DIRECTION OF THE OFFICE OF

THE UNDER SECRETARY FOR HEALTH

/s/ RimaAnn O. Nelson

Assistant Under Secretary for Health
for Operations

NOTE: All references herein to VA and VHA documents incorporate by reference

subsequent VA and VHA documents on the same or similar subject matter.

DISTRIBUTION: Emailed to the VHA Publications Distribution List on January 27, 2022.

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CONTENTS

CORONAVIRUS DISEASE 2019 VACCINATION PROGRAM FOR VETERANS

HEALTH ADMINISTRATION HEALTH CARE PERSONNEL

1. PURPOSE ................................................................................................................... 1

2. BACKGROUND ........................................................................................................... 1

3. DEFINITIONS .............................................................................................................. 3

4. POLICY ....................................................................................................................... 5

5. RESPONSIBILITIES.................................................................................................... 6

6. REFERENCES .......................................................................................................... 11

APPENDIX A

PROCEDURES FOR IMPLEMENTING THE COVID-19 VACCINATION PROGRAM AT

VHA LOCATIONS .................................................................................................... A-1

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January 27, 2022 VHA DIRECTIVE 1193.01

CORONAVIRUS DISEASE 2019 VACCINATION PROGRAM FOR VETERANS

HEALTH ADMINISTRATION HEALTH CARE PERSONNEL

1. PURPOSE. This Veterans Health Administration (VHA) directive establishes policy

and provides guidance for the prevention of coronavirus disease 2019 (COVID-19) in
VA medical facilities through the vaccination of VHA HCP. It provides procedures for
VHA HCP to submit proof of a complete COVID-19 vaccination series and request
accommodation to the vaccination requirement. It includes workplace safety protocols
VHA HCP are expected to follow and describes procedures for noncompliance with this
policy. NOTE: This policy, VHA Directive 1193.01, reissues and revises the August 13,
2021, publication of VHA Directive 1193, which was superseded on October 4, 2021.
VHA Notice 2021-18 which published the superseding of VHA Directive 1193 is
rescinded by this directive. AUTHORITIES:

a. 38 U.S.C. § 7301(b).

b. 38 U.S.C. § 7318(b).

c. 38 U.S.C. § 7421, Personnel Administration: in general.

d. 5 C.F.R. § 339.205, Medical Evaluation Programs.

e. Executive Order 13991, Protecting the Federal Workforce and Requiring Mask-
Wearing.

f. OPM Approved Variation to 5 C.F.R. § 339.205 dated August 11, 2021.

2. BACKGROUND

a. The emergence of SARS-CoV-2, the virus that causes COVID-19, has led to a
global pandemic with dramatic societal and economic impact on individuals and
communities since late 2019. To combat this ongoing global health threat, and to
reduce the risk of symptomatic laboratory-confirmed COVID-19, hospitalization due to
COVID-19, and associated deaths, the Centers for Disease Control and Prevention
(CDC) and its Advisory Committee on Immunization Practices (ACIP) recommends
everyone 5 years of age and older receive a COVID-19 vaccination.

b. Recognized modes of SARS-CoV-2 transmission are via inhalation of very small

droplets and aerosol particles that contain infectious virus, deposition of virus carried in
exhaled droplets and particles onto exposed mucous membranes, and touching mucous
membranes with hands soiled by exhaled respiratory fluids containing virus or from
touching inanimate surfaces contaminated with virus. Some of these modes are similar
to other respiratory pathogens that cause severe acute viral respiratory syndromes.
Very small droplets and aerosol particles can land in the mouths or noses of people who
are within approximately 3 to 6 feet from an infected person or possibly be inhaled into
the lungs.

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c. Changes in SARS-CoV-2 can lead to emergence of new variants. Such variants,

such as the Delta variant and the Omicron variant, have different characteristics. New
variants can produce changes in viral transmission and changes in the the risks of
severe illness, hospitalization, and death. Vaccination remains the safest strategy for
protecting against contracting SARS-CoV-2 and decreasing emergence of new viral
variants.

d. The advent of vaccines does not eliminate the grave danger from exposure to
SARS-CoV-2 in workplaces where some members of the workforce are not fully
vaccinated and patients may not be vaccinated. In fact, VHA community living centers
(CLCs), without fully vaccinated staff introduce a potentially significant source of SARS-
CoV-2 infections leading to ongoing viral transmission among vulnerable populations in
the CLCs. In addition, transmission of circulating viral variants raises public health
concerns that hospitalization rates will rise, along with serious or fatal outcomes for
those who contract COVID-19. As of January 24, 2022, there have been 549,814
Veteran and employee cases of COVID-19 in VA, and 18,725 known deaths. Greater
than 52,000 of these COVID-19 cases have occurred among VA staff. During the same
period, over 320,936 employees and other health care personnel in VHA have been
fully vaccinated against COVID-19. NOTE: VA COVID-19 National Summary is
available at: https://www.accesstocare.va.gov/Healthcare/COVID19NationalSummary.

e. Society and professional norms set the expectation that HCP “do no harm” to the
patients they treat and serve. Employees of VA work to serve Veterans as part of the
health care system and have a duty to protect their colleagues and the HCP with whom
they may interact. This expectation can reasonably be applied to all health care staff in
interactions with their colleagues such that employees of VA who work to serve
Veterans as part of the health care system also have a duty to protect their colleagues.
Accordingly, employees must take every reasonable step to prevent transmission of
SARS-CoV-2 in VA medical facilities. Among other prevention efforts, which may
include masking, social distancing, respiratory etiquette, and hand hygiene, vaccination
against COVID-19 is fundamental to the prevention of COVID-19 for both patients and
staff, and to the mitigation of transmission of this virus among susceptible populations in
the workplace.

f. More than 529 million doses of COVID-19 vaccine have been given in the United
States from December 14, 2020, through January 18, 2022, with the most robust safety
monitoring in vaccine history. COVID-19 vaccines have been administered since
receiving emergency use authorization by the Food and Drug Administration (FDA) with
rare serious adverse reactions reported after vaccination. All FDA-authorized or
approved COVID-19 vaccines are safe and effective and reduce the risk of severe
disease, hospitalization, and death due to COVID-19.

g. In addition to CDC and ACIP, other preeminent health care organizations, such as
the American Medical Association, American Nurses Association, American Hospital
Association, the Association of American Medical Colleges, among others, urge the
public to get vaccinated against COVID-19. Additional information about supporting
organizations can be found here: Supporting OSHA COVID-19 vaccine mandates |

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January 27, 2022 VHA DIRECTIVE 1193.01

American Medical Association (ama-assn.org). Moreover, the American College of

Physicians strongly encourages vaccination of physicians, other health care
professionals, and patients when available. On July 13, 2021, a Multisociety Statement
from the leading Infectious Diseases Societies was issued in the Infection Control &
Hospital Epidemiology journal recommending that the COVID-19 vaccination should be
a condition of employment for all health care personnel. Additional information about
supporting organizations can be found here: Supporting OSHA COVID-19 vaccine
mandates | American Medical Association (ama-assn.org). NOTE: The Multisociety
Statement is available at: https://www.cambridge.org/core/journals/infection-control-and-
hospital-epidemiology/article/multisociety-statement-on-covid19-vaccination-as-a-
condition-of-employment-for-healthcare-
personnel/690D1804B72FFF89C5FC0AED0043AD62#. This website is outside VA
control and may not conform to Section 508 of the Rehabilitation Act of 1973.

3. DEFINITIONS

a. Face Mask. For the purposes of this directive, a face mask is a disposable
surgical, medical procedure, dental, or isolation mask, provided by VHA, that covers the
nose and mouth and fits snugly against the sides of face without gaps. Masks and
respirators are effective at reducing transmission of SARS-CoV-2, the virus that causes
COVID-19, when worn consistently and correctly. Face masks should be worn as
outlined in local and national policies. NOTE: Fitted N95 respirators or other
respirators are not required by this policy, but they should be used when appropriate to
the task (e.g., when caring for a patient on airborne infection isolation precautions). If
N95 or higher respirators are used, they also serve the purpose of being considered a
face mask for this directive. VHA guidance further expands the use of voluntary N95
masks (filtering facepieces).

b. Health Care Personnel. Healthcare personnel (HCP) refers to all paid and
unpaid persons who work in or travel to VHA locations who have the potential for direct
or indirect exposure to patients or infectious materials, including body substances (e.g.,
blood, tissue, and specific body fluids); contaminated medical supplies, devices, and
equipment; contaminated environmental surfaces; or contaminated air. These HCP may
include, but are not limited to, emergency medical service personnel, nurses, nursing
assistants, physicians, technicians, therapists, phlebotomists, pharmacists, health
professions trainees (HPTs), and persons (e.g., clerical, dietary, environmental
services, laundry, security, maintenance, engineering and facilities management,
administrative, billing, and volunteer personnel) not directly involved in patient care but
potentially exposed to infectious agents that can be transmitted from HCP and patients.
HCP include all VA licensed and unlicensed, clinical and administrative, paid and
without compensation, full- and part-time, intermittent, fee basis employees who are
expected to perform any or all of their work at these locations. HCP also includes VHA
personnel providing home-based care to Veterans and drivers and other personnel
whose duties put them in contact with patients outside VA medical facilities.

NOTE: VHA HCPs do not include remote workers who only infrequently enter VHA
locations.

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NOTE: VA employees who work in VHA locations but are not part of VHA are not
covered by the contents of this Directive.

c. Fully Vaccinated. The definition of fully vaccinated will be in accordance with

current CDC definitions. At the time of publication, the CDC considers an individual
“fully vaccinated” for COVID-19 two weeks after receipt of the requisite number of doses
of a COVID- 19 vaccine either approved or authorized for emergency use by the FDA or
that has been listed for emergency use by the World Health Organization (WHO). For
Pfizer-BioNTech, Moderna, or AstraZeneca/Oxford, that is two weeks after an employee
has received the second dose of a two-dose series. For Johnson and Johnson
(J&J)/Janssen, that is two weeks after receipt of a single-dose. Clinical trial participants
from a United States 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, are considered fully vaccinated two weeks after they complete
the vaccine series. Currently, the Novavax COVID-19 vaccine meets these criteria.
There is currently no post-vaccination time limit to retain fully vaccinated status. NOTE:
For more information, CDC guidelines are available at:
https://www.cdc.gov/vaccines/covid-19/clinical-considerations/covid-19-vaccines-
us.html#people-vaccinated-outside-us.

d. Government-wide travel restrictions. Restrictions on official government travel

due to COVID-19 are established by the Safer Federal Workforce Task Force COVID-
19 Workplace Safety: Agency Model Safety Principles. Restrictions on official
government travel are outlined in VA travel policy and communicated in the Office of
Human Resources and Administration/Operations, Security and Preparedness
(HRA/OSP), Office of the Chief Human Capital Officer (OCHCO) Bulletins and VA
Administration-specific policies.

e. Physical distancing. CDC and the Occupational Safety and Health

Administration (OSHA) define physical distancing as maintaining a sufficient distance
between two people such that the risk of disease transmission through inhalation of
virus-containing particles from an infected individual is significantly reduced. Adequate
physical distancing to prevent droplet transmission of infectious diseases is generally
considered to be at least six (6) feet when indoors. This term is also referred to as social
distancing.

f. VHA Locations. VHA locations include, but are not limited to, VA medical facilities
(hospitals) and associated clinics, community living centers (CLCs), community-based
outpatient clinics (CBOCs), domiciliary units, Vet centers and VA-leased medical
facilities.

g. COVID-19 Vaccine. According to the CDC, the COVID-19 vaccine is defined as

an FDA-approved or authorized commercially available product recommended by the
CDC for the prevention of COVID-19. Employees who have already been vaccinated
with or, in the event there is limited supply, elect to be vaccinated with any CDC
recommended vaccine series under emergency use authorization by the FDA or listed
for emergency use by the WHO, will be considered as having met the requirements

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under this Directive. CDC guidelines should be followed to determine whether

individuals who received COVID-19 vaccines that are not approved or authorized by
FDA may be considered fully vaccinated. NOTE: For more information, CDC website is
available at: https://www.cdc.gov/coronavirus/2019-ncov/index.html.

h. Accommodation Request. A request for an accommodation, for the purpose of

this directive, is a request to change, modify, or remove the workplace requirement to
be fully vaccinated against COVID-19, on the basis of pregnancy or religion under Title
VII or on the basis of disability under the Rehabilitation Act/Americans with Disabilities
Act, as amended.

i. Remote employee. An employee approved for a special type of arrangement as

defined in VA Handbook 5011, Part II, Chapter 4 under which an employee is scheduled
to perform work within or outside the local commuting area of an agency worksite and is
not expected to report to the agency worksite on a regular and recurring basis.
Employees on approved full-time telework that are not expected to report to the office
due to a temporary accommodation granted during the COVID-19 pandemic are not
considered remote employees. Remote employees are not covered by this notice.

j. Telework employee. An employee that is approved for a flexible work

arrangement as defined in VA Handbook 5011, Part II, Chapter 4 under which an
employee performs the duties and responsibilities of their position and other authorized
activities, from an approved worksite other than the location from which the employee
would otherwise work. Teleworking employees are required to report to the agency
worksite at least twice each pay period on a regular, recurring basis unless a temporary
accommodation applies. Telework employees are covered by this notice.

k. Virtual employee. An employee who performs “virtual work” as defined in VA

Handbook 5011, Part II, Chapter 4. Virtual work is defined as work performed on a full-
time basis using a VA-leased space or at a VA facility other than the facility that hired
the employee. Virtual employees must adhere to all local safety measures in place for
COVID-19 at the VA-leased space or VA facility where they perform work. Virtual
employees are only covered by this notice when the space in which work is performed
is a VHA location in which the employee has the potential for direct or indirect exposure
to patients or infectious materials, including body substances (e.g., blood, tissue, and
specific body fluids); contaminated medical supplies, devices, and equipment;
contaminated environmental surfaces; or contaminated air.

4. POLICY

a. It is VHA policy that all VHA Health Care Personnel (HCP) are required to be fully
vaccinated against COVID-19 or obtain an approved accommodation for medical,
pregnancy, or religious reasons, when required by law. All VHA entities will implement a
mandatory COVID-19 vaccination program by requiring all VHA HCP to be fully
vaccinated or obtain an accommodation. Compliance with this directive is a
requirement. VHA HCP in violation of this directive may face disciplinary action up to
and including removal from Federal service.

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b. VHA HCP are required to provide acceptable proof of vaccination status (as
defined in this directive) and certify under penalty of perjury that the documentation
submitted is true and correct, even if an employee has previously attested to their
vaccination status. Employees who have provided acceptable proof of vaccination
under VA Notice 22-01 are compliant with this requirement.

c. Information provided by the employee will be protected as required by the Privacy

Act, and any other relevant statute, regulation, or VA policy.

d. When there is an urgent mission-critical hiring need to onboard new employees in

HCP positions prior to those individuals being fully vaccinated, an extension to the
vaccination requirement may be approved by the field facility head. When such
extensions are approved, the newly hired employee(s) must be fully vaccinated or
request an accommodation within 60 calendar days of their start date and follow safety
protocols for not fully vaccinated individuals until they are fully vaccinated. This cannot
be used for positions designated on VA Form 10230a.

5. RESPONSIBILITIES

a. Under Secretary for Health. The Under Secretary for Health is responsible for
the overall administration and compliance with this directive.

b. Assistant Under Secretary for Health for Operations. The Assistant Under
Secretary for Health for Operations is responsible for:

(1) Communicating the contents of this directive to each of the VISNs.

(2) Assisting VISN Directors to resolve implementation and compliance challenges in

all VA medical facilities within that VISN.

(3) Providing oversight of the VISNs to ensure compliance with this directive and its
effectiveness.

(4) Collaborating with the Assistant Under Secretary for Health for Support Services
and the Assistant Under Secretary for Health for Quality and Patient Safety to support
monitoring, reporting and evaluation of the impact of this directive.

(5) Designating management officials outside of immediate supervisors, if

applicable, to decide requests for accommodation to the vaccination workplace
requirement and any associated requests for accommodations for mitigating measures
in VHA Field Facilities.

c. The Director of VHA Analytics, Performance and Integration shall aggregate,

analyze, and report to the facility leadership all metrics for the purposes of evaluating
the COVID-19 vaccination program. Personally Identifiable Information (PII) and
Personal Health Information (PHI) are subject to the Privacy Act, and the regulations
promulgated under the Health Insurance Portability and Accountability Act (HIPAA
Rules). The information may not be used or disclosed unless an individual has a

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legitimate need to know the information in the performance of their duties or as

otherwise permitted by law.

d. Medical Advisor, Office of Occupational Safety and Health. The Medical

Advisor, VHA Office of Occupational Safety and Health is responsible for collaborating
with the National Center for Health Promotion and Disease Prevention to provide further
guidance on policies, procedures, education and training resources for COVID-19
vaccination.

e. Veterans Integrated Service Network Director. Each VISN Director is

responsible for:

(1) Ensuring that necessary resources are available to implement and oversee the
COVID-19 vaccination program for VHA HCP in the VISN.

(2) Ensuring that all facilities within the VISN participate in oversight activities for the
purposes of evaluating the COVID-19 vaccination program for VHA HCP.

f. Field facility director, field facility head, and program office heads. Each VHA
medical facility Director is responsible for:

(1) Ensuring that all aspects of this directive are implemented at their facility.

(2) Ensuring VHA HCP have access to available training or education pertaining to
proper use of face masks and other mitigation strategies that reduce the spread of
SARS-CoV-2, the virus that causes COVID-19, including how to access face masks,
when to wear a mask, the appropriate type of mask to wear, when to replace a mask,
and proper disposal of masks, according to local conditions.

(3) Ensuring all VHA HCP are notified of the requirement to participate in the
COVID-19 vaccination program, as described in Appendix A.

(4) Ensuring VHA HCP have access to information on: the current CDC Vaccine
Information Statement (VIS) or Emergency Use Authorization Fact Sheet for Recipients
and Caregivers; the package inserts for COVID-19 vaccines used by the VA medical
facility; and COVID-19 vaccine including vaccinator and handler training.

(5) Addressing non-compliant VHA HCP, in conjunction with the supervisor and
Chief Human Resources Officer, as necessary.

g. Chief Human Resources Officer. The Chief of Human Resources Officer for
each servicing human resource office is responsible for:

(1) Notifying prospective employees, of the mandatory COVID-19 vaccination

program in job opportunity announcements and tentative and final offers.

(2) Providing advice and guidance on addressing non-compliant employees, in

conjunction with the supervisor and the Office of General Counsel as necessary.

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(3) Ensuring all administrative actions taken in response to this directive are
recorded in accordance with VA Notice 22-02, Use of the Automated Labor and
Employee Relations Tracker (ALERT-HR).

(4) Facilitate the reassignment process for employees who cannot have
accommodations granted in their position of record in accordance with VA Notice 22-04,
Processing Reassignments as a Reasonable Accommodation Regarding the COVID-19
Vaccination Mandate.

(5) Ensuring appropriate record retention for all files related to accommodation
requests.

h. Chief, Voluntary Service. The Chief, Voluntary Service or other designated

official at each VA medical facility is responsible for:

(1) Notifying all current and prospective volunteers in HCP positions about the
COVID-19 vaccination program’s vaccination requirement and providing them with
information about how to comply with this directive.

(2) Counselling those volunteers who are not compliant with the requirements set by
this directive and implementing actions determined by the VA medical facility Director or
designee for volunteers found to be in violation of this directive.

(3) Entering volunteer information into the electronic tracking system as necessary.

i. VA Medical Facility Designated Education Officer (DEO) or Designee. The

DEO or his/her designee at each VA medical facility is responsible for all facility HPTs
and:

(1) Ensuring through the Trainee Qualifications and Credentials Verification Letter
(TQCVL) process that each academic affiliate, appropriate training program official and
HPT is aware of the VHA COVID-19 vaccination program requirements stated below.

NOTE: The TQCVL guide is available at: https://www.va.gov/oaa/deo.asp. For

information on local implementation of the TQCVL process, contact the VA medical
facility DEO.

(2) Receiving and maintaining trainee compliance certification via the TQCVL for all
HPTs including paid and without compensation.

(3) Communicating with the academic affiliate and appropriate individuals at the VA
medical facility about the necessity of HPT compliance with this policy.

(4) Monitoring trainee compliance and documentation is the responsibility of the

DEO.

j. VHA Health Care Personnel. VHA HCP are required to comply with this directive
by:

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(1) Receiving a complete COVID-19 vaccine series by applicable deadlines or, if an

accommodation is requested and approved, wearing a face mask, physically distancing,
following Government-wide travel restrictions, and complying with additional mitigation
requirements such as, but not limited to, COVID-19 testing, absent additional
accommodations.

(2) Submitting the required information in the designated VA system for electronic
submission or a completed COVID-19 Vaccination Form, VA Form 10230c (or VA Form
10230 prior to publication of this Directive) and attaching proof of vaccination or
completing a voluntary release of information form (VA 10-5345) to disclose the VA
vaccination record (if vaccinated through Employee Occupational Health). The
documentation must include information about 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). Acceptable forms of documentation include a copy of the
signed record of immunization from a health care provider or pharmacy, a copy of the
COVID-19 Vaccination Record Card (CDC Form MLS-319813_r, published on
September 3, 2020), 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 information.

(3) VHA HCPs who previously submitted VA Form 10230 or in the VA system for
electronic submission, with complete documentation as defined in this directive, are
considered compliant.

(4) If a VHA HCP is seeking an accommodation to being fully vaccinated for medical,
pregnancy, or religious reasons, the VHA HCP must complete the required information
using the designated VA system for electronic submission, or should submit a
completed COVID-19 Vaccination Form, VA Form 10230c, requesting an
accommodation, acknowledging the requirement to wear a face mask, physically
distance, be subject to Government-wide travel restrictions, and required COVID-19
testing and any other mitigation requirements, absent additional accommodations. The
form must be submitted to the employee’s supervisor.

(a) To request an accommodation for a medical condition, the VHA HCP should
indicate they are requesting an accommodation using the designated system for
electronic submission, VA Form 10230c, or by providing documentation identified in
national collective bargaining agreement(s). Prior to the publication of this directive, VA
Form 10230 was acceptable for submission and these requests will not require
resubmission. If a VHA HCP requests a medical accommodation, the Management
Official/supervisor is required to engage in the reasonable accommodation process in
accordance with VA Directive 5975, Diversity and Inclusion, VA Handbook 5975.1,
Processing Requests for Reasonable Accommodation from Employees and Applicants
with Disabilities, VA Notice 22-04, Processing Requests as a Reasonable
Accommodation Regarding the COVID-19 Vaccine Mandate, and processing guidance
found on VA Form 10230a.

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(b) To request an accommodation under Title VII for religious or pregnancy related
reasons, the VHA HCP should indicate they are requesting an accommodation using
the designated system for electronic submission, VA Form 10230c, or by providing
documentation identified in national collective bargaining agreement(s). Prior to the
publication of this directive, VA Form 10230 was acceptable for submission and these
requests will not require resubmission. If a VHA HCP requests an accommodation for
religion or pregnancy, the Management Official/supervisor is required to engage in the
reasonable accommodation process in accordance with VA Directive 5975, Diversity
and Inclusion, VA Notice 22-04, Processing Reassignments as a Reasonable
Accommodation Regarding the COVID-19 Vaccine Mandate, and processing guidance
found on VA Form 10230a, VA Form 10230b, Title VII Accommodation Request
Determination: Religious or Pregnancy, and the COVID-19 Vaccination Mandate and
Religious Accommodations job aid for supervisors. The Management Official/supervisor
may consult with religious accommodation advisors, human resources, Local
Reasonable Accommodation Coordinators, or the Office of General Counsel for
guidance on the request.

(c) While a request for accommodation for medical, pregnancy or religious reasons
is being reviewed, the employee will wear a face mask, physically distance, and submit
to COVID-19 testing (and any other mitigation requirements) as prescribed in VA policy,
VHA policy, and any other approved interim accommodation, absent any applicable
accommodation request. Official travel will also be restricted in accordance with
applicable VA travel guidance.

(d) Face masks must be worn as outlined in local and national VA policies and in
accordance with collective bargaining agreements and memoranda of understanding
with labor unions.

k. Applicants. Applicants, internal and external must be fully vaccinated prior to

entrance on duty and provide proof of vaccination in the manner outlined in this
directive. Circumstances in which applicants are not required to be fully vaccinated prior
to entrance on duty include:

(1) Applicants for whom a reasonable accommodation is legally required.

(2) When there is an emergent mission-critical hiring need allowing a 60-day

extension to being fully vaccinated prior to beginning VA employment.

(3) When the Deputy Under Secretary for Health has approved a timeframe during
which applicants, internal and external, with accommodation requests may be brought
onboard prior to adjudication of their requests, outside of positions designated as high
risk on the VA Form 10230a.

l. Supervisors. Supervisors shall:

(1) Document and track issues of non-compliance with the COVID-19 vaccination
policy, including adherence to masking and testing requirements.

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(2) Consult with CHROs, LRACs, and the Office of General Counsel to address
employees that are non-compliant with this directive.

(3) Engage in the reasonable accommodation process in accordance with VA

Directive 5975: Diversity and Inclusion, VA Handbook 5975.1: Processing Requests for
Reasonable Accommodation from Employees and Applicants with Disabilities,
processing guidance found on VA Form 10230a, the COVID-19 Vaccination Mandate
and Religious Accommodations job aid for supervisors for religious accommodation
requests, and VA Notice 22-04, Processing Requests as a Reasonable Accommodation
Regarding the COVID-19 Vaccine Mandate, unless another authority is designated by
the Under Secretary for Health. Supervisors may consult with the religious
accommodation advisor(s), Local Reasonable Accommodation Coordinators, servicing
Human Resources, and the Office of General Counsel for guidance on such
accommodation requests.

(4) Ensure that the information entered through electronic submission or submission
of a physical copy of VA Form 10230c, proof of vaccination is kept secure and
confidential under the system of records notice OPM/GOVT-10 or 08VA05, as
applicable.

m. Management Officials/Supervisor on Accommodation Requests.

Management Officials/supervisors will, as applicable:

(1) Assess employee requests for accommodation utilizing VA Form 10230a.

(2) Engage in the interactive process before making decisions on requests.

(3) Adjudicate requests for accommodation and finalize the required forms to
document the decision.

(4) Notify human resources to initiate the reassignment process when an employee
cannot be accommodated in their position of record.

n. Local Reasonable Accommodation Coordinators (LRAC). LRACs shall

process requests for reasonable accommodations based on medical conditions in
accordance with VA Handbook 5975.1, Processing Requests for Reasonable
Accommodations for Applicants and Employees, and VA Notice 22-04, Processing
Requests as a Reasonable Accommodation Regarding the COVID-19 Vaccine
Mandate. They will consult on requests for accommodation for pregnancy or religious
reasons, when assigned by Chief Human Resource Officers, and will maintain
documentation for all requests for accommodation to the COVID-19 vaccination
requirement.

6. REFERENCES

a. 38 U.S.C. §§ 7301(b), 7318(b), 7421.

b. 29 C.F.R. § 1910.

11
January 27, 2022 VHA DIRECTIVE 1193.01

c. 5 C.F.R. Part 339 – Medical Qualification Determinations.

d. VA Handbook 5019, Employee Occupational Health Service, dated August 3,

2017.

e. VA Form 10230a, Undue Hardship Review

f. VA Form 10230b, Title VII Accommodation Request Determination: Religious or

Pregnancy

g. VA Form 10230c, COVID-19 Vaccination Form for VHA HCPs is available at:
https://vaww.va.gov/vaforms/ and https://www.va.gov/find-forms/. NOTE: The first link is
an internal VA website that is not available to the public. To access the form, type VA
Form 10230c into the search bar.

h. VHA HANDBOOK 5975.1, Processing Requests for Reasonable Accommodation

from Employees and Applicants with Disabilities.

i. VA Handbook 5975, Diversity and Inclusion.

j. Multisociety Statement on COVID-19 Vaccination as a Condition of Employment

for Healthcare Personnel: https://www.cambridge.org/core/journals/infection-control-
and-hospital-epidemiology/article/multisociety-statement-on-covid19-vaccination-as-a-
condition-of-employment-for-healthcare-
personnel/690D1804B72FFF89C5FC0AED0043AD62. NOTE: This website is outside
VA control and may not conform to Section 508 of the Rehabilitation Act of 1973.

k. VA. Department of Veterans Affairs. VA COVID-19 National Summary:

https://www.accesstocare.va.gov/Healthcare/COVID19NationalSummary.

l. Centers for Disease Control and Prevention (CDC). ACIP Interim List of
Categories of Essential Workers Mapped to Standardized Industry Codes and Titles.
March 29, 2021: https://www.cdc.gov/coronavirus/2019-ncov/index.html

m. CDC. Guidance for Wearing Masks. Types of Masks and Respirators | CDC.

n. CDC. Kambhampati, et al. COVID-19–Associated Hospitalizations Among Health

Care Personnel — COVIDNET, 13 States, March 1–May 31, 2020. Morbidity and
Mortality Weekly.30 October 2020:
https://www.cdc.gov/mmwr/volumes/69/wr/mm6943e3.htm?s_cid=mm6943e3_x.

o. CDC. National Center for Health Statistics. Vital and Health Statistics. 2019
February: https://www.cdc.gov/nchs/data/series/sr_03/sr03_43-508.pdf.

p. CDC. Oliver S, Gargano J, Marin M, et al. The Advisory Committee on

Immunization Practices’ Interim Recommendation for Use of Pfizer-BioNTech COVID-
19 Vaccine — United States, December 2020. MMWR Morb Mortal Wkly Rep

12
January 27, 2022 VHA DIRECTIVE 1193.01

2020;69:1922-1924:
https://www.cdc.gov/mmwr/volumes/69/wr/mm6950e2.htm?s_cid=mm6950e2_w

q. CDC. Oliver S, Gargano J, Marin M, et al. The Advisory Committee on

Immunization Practices’ Interim Recommendation for Use of Moderna COVID-19
Vaccine — United States, December 2020. MMWR Morb Mortal Wkly Rep
2021;69:1653-1656:
https://www.cdc.gov/mmwr/volumes/69/wr/mm695152e1.htm?s_cid=mm695152e1_w.

r. CDC. Oliver SE, Gargano JW, Scobie H, et al. The Advisory Committee on
Immunization Practices’ Interim Recommendation for Use of Janssen COVID-19
Vaccine — United States, February 2021. MMWR Morb Mortal Wkly Rep 2021;70:329–
332: https://www.cdc.gov/mmwr/volumes/70/wr/mm7009e4.htm?s_cid=mm7009e4_w

s. CDC. Post-vaccination considerations for workplaces:

https://www.cdc.gov/coronavirus/2019-ncov/community/workplaces-
businesses/vaccination-considerations-for-workplaces.html.

t. CDC. Post Vaccine Considerations for Residents:

https://www.cdc.gov/coronavirus/2019-ncov/hcp/post-vaccine-considerations-
residents.html.

u. CDC. Wallace M, Woodworth KR, Gargano JW, et al. The Advisory Committee on
Immunization Practices’ Interim Recommendation for Use of Pfizer-BioNTech COVID-
19 Vaccine in Adolescents Aged 12–15 Years — United States, May 2021. MMWR
Morb Mortal Wkly Rep 2021;70:749–752:
https://www.cdc.gov/mmwr/volumes/70/wr/mm7020e1.htm?s_cid=mm7020e1_w

v. CDC. Self WH, Tenforde MW, Stubblefield WB, et al. Seroprevalence of SARS-
CoV-2 Among Frontline Health Care Personnel in a Multistate Hospital Network — 13
Academic Medical Centers, April–June 2020. MMWR Morb Mortal Wkly Rep
2020;69:1221–1226: https://www.cdc.gov/mmwr/volumes/69/wr/mm6935e2.htm.

w. CDC. Scientific Brief: SARS-CoV-2 Transmission. May 7 2021:

https://www.cdc.gov/coronavirus/2019-ncov/science/science-briefs/sars-cov-2-
transmission.html.

x. CDC. Slayton, Rachel B. Modeling Allocation Strategies for the Initial SARS-CoV-
2 Vaccine Supply. Presented for the Advisory committee on Immunization practices 26
August 2020: https://www.cdc.gov/vaccines/acip/meetings/downloads/slides-2020-
08/COVID-06-Slayton.pdf.

y. CDC. United States COVID-19 Cases and Deaths by State:

https://covid.cdc.gov/covid-data-tracker/#cases_casesper100klast7days.

z. CDC. Updated Healthcare Infection Prevention and Control Recommendations in

Response to COVID-19 Vaccination: https://www.cdc.gov/coronavirus/2019-
ncov/hcp/infection-control-after-vaccination.html.

13
January 27, 2022 VHA DIRECTIVE 1193.01

aa. Centers for Medicare and Medicaid Services (CMS). COVID-19 Nursing Home
Data: https://data.cms.gov/stories/s/COVID-19-Nursing-Home-Data/bkwz-xpvg/.

bb. Equal Employment Opportunity Commission (EEOC). Pandemic Preparedness

in the Workplace and the Americans with Disabilities Act:
https://www.eeoc.gov/wysk/what-you-should-know-about-covid-19-and-ada-
rehabilitation-act-and-other-eeo-laws.

cc. American College of Physicians (ACP). ACP Supports ACIP Recommendation

for COVID-19 Vaccination. December 15, 2020: https://www.acponline.org/acp-
newsroom/acp-supports-acip-recommendation-for-covid-19-vaccination. NOTE: This
website is outside VA control and may not conform to Section 508 of the Rehabilitation
Act of 1973.

dd. Geoghegan S, Kitt E, Offit P. COVID-19 Vaccination in Health Care Workers.

Infectious Disease Special Edition. Fall 2019. 75-79:
https://www.idse.net/download/FluVaccine_IDSE0919_WM.pdf. NOTE: This website is
outside VA control and may not conform to Section 508 of the Rehabilitation Act of
1973.

ee. Gostin, L.O., Salmon, D.A., Larson, H.J. (2021). Mandating COVID-19 vaccines.
JAMA, 325(6), 532-533: https://jamanetwork.com/journals/jama/fullarticle/2774712.
NOTE: This website is outside VA control and may not conform to Section 508 of the
Rehabilitation Act of 1973.

ff. Moscola J, Sembajwe G, Jarrett M, et al. Prevalence of SARS-CoV-2 Antibodies

in Health Care Personnel in the New York City Area. JAMA. 2020;324(9):893–895.
doi:10.1001/jama.2020.14765: https://jamanetwork.com/journals/jama/article-
abstract/2769322. NOTE: This website is outside VA control and may not conform to
Section 508 of the Rehabilitation Act of 1973.

gg. Nguyen et al. Risk of COVID-19 among front-line health-care workers and the
general community: a prospective cohort study. Lancet. 1 September 2020. Accessed 9
Nov 2020 at https://www.thelancet.com/journals/lanpub/article/PIIS2468-
2667(20)30164-X/fulltext. NOTE: This website is outside VA control and may not
conform to Section 508 of the Rehabilitation Act of 1973.

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January 27, 2022 VHA DIRECTIVE 1193.01
Appendix A

PROCEDURES FOR IMPLEMENTING THE COVID-19 VACCINATION PROGRAM AT

VHA LOCATIONS

1. NOTIFICATION OF MANDATORY COVID-19 VACCINATION AMONG HEALTH

CARE PERSONNEL IN THE VETERANS HEALTH ADMINISTRATION

a. Chief Human Resources Officers (CHRO)/Human Capital Management (HCM)

will notify all VHA HCPs that they are required to participate in the COVID-19
vaccination program. Employees will be notified through their respective servicing
human resource offices.

b. Each VHA facility or program office will provide no less than two such notifications
under this directive within two weeks after original publication of this Directive.
Notifications are considered complete when previously issued under former VHA
Directive 1193 or VA Notice 22-01. VHA HCP covered under VHA Directive 1193 and/or
VA Notice 22-01 were required to receive a complete COVID-19 vaccine series by
October 8, 2021.

c. Human Resources will notify prospective employees who will be HCPs who begin
work after publication of the mandatory COVID-19 vaccination program in job
opportunity announcements and tentative and final offer letters. New employees who
will be HCPs who are scheduled to begin VHA employment or change positions within
VHA on or after the date of publication, will be required to provide proof they are fully
vaccinated prior to onboarding or will be advised they may request an accommodation
for disability, pregnancy, or religious reasons prior to the individual’s entrance on duty. If
a new employee does not provide the required proof of vaccination status or have an
approved accommodation, the new employee may not be extended a final offer of
employment. Circumstances in which applicants are not required to be fully vaccinated
prior to entrance on duty include:

(1) Applicants for whom a reasonable accommodation is legally required and

approved;

(2) When there is an emergent mission-critical hiring need allowing a 60-day

extension to being fully vaccinated prior to beginning VA employment as approved by
the field facility head; or

(3) When the Deputy Under Secretary for Health has approved a timeframe during
which applicants, internal and external, with accommodation requests may be brought
onboard prior to adjudication of their requests, outside of positions designated as high
risk on the VA Form 10230a.

2. VACCINE PROGRAM COMPLIANCE

a. VHA HCP. All VHA HCP must comply by submitting the required information in
the identified VA electronic system (or a completed VA Form 10230c) to the supervisor.

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Appendix A

(1) Current VHA HCP hired on or before publication of this policy are considered
compliant when the required information is submitted in the identified VA electronic
system (or a completed VA Form 10230) furnished to the supervisor no later than
October 18, 2021, or within 14 days of the date onboarded at VA.

(2) Applicants and newly hired HCP onboarding on or after the date of publication of
this directive must comply with documentation requirements within 14 days from the
entrance on duty date.

b. The completed information submitted electronically (or on VA Form 10230c) must

include:

(1) Documentation showing receipt of a complete COVID-19 vaccine series; or

(2) Documentation requesting an accommodation to being fully vaccinated.

The VA Form 10230c is available at: https://vaww.va.gov/vaforms/ and

https://www.va.gov/find-forms/.

c. Proof of Vaccination.

(1) If a VHA HCP is vaccinated by VA, in lieu of submitting proof of vaccination, an

employee may voluntarily elect to sign a release of information form (VA Form 10-5345)
for the VA to release the information to the supervisor. The information released to the
supervisor is limited to the information required to verify receipt of the required COVID-
19 vaccine doses (type of vaccine administered, date(s) of administration, and the name
of the healthcare professional(s) or clinic site(s) administering the vaccine(s)).

(2) If a VHA HCP is vaccinated outside of VA, the employee must complete the
required information in the designated VA electronic system (or VA Form 10230c). The
employee must attach acceptable documentation verifying vaccination in the designated
electronic system or with the accompanying VA Form 10230c delivered to the
supervisor.

NOTE: Acceptable documentation includes a signed record of immunization from a

health care provider or pharmacy, a copy of the COVID-19 Vaccination Record Card
(CDC Form MLS-319813_r, published on September 3, 2020), a copy of immunization
records from a public health or state immunization information systems, a copy of
medical records documenting the vaccination, or a copy of any other official
documentation containing all data points required.

d. Compliance When an Accommodation Applies.

(1) If a VHA HCP is requesting an accommodation to being fully vaccinated for

medical, religious, or pregnancy related reasons, the employee should complete the
required information in the designated VA system for electronic submission (or VA Form
10230c) or make the request through another appropriate mechanism as outlined
above. Requesting an accommodation requires acknowledging the requirement to wear

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Appendix A

a face mask, physically distance, undergo COVID-19 testing, sign an authorization to

release test results, and any other mitigation strategies when under conditions in the
work environment as outlined in national VA guidance, absent additional
accommodations. COVID-19 testing will be performed as determined necessary to
maintain safe work environments.

e. VA Applicants and New Employees. New VHA HCP employees (both internal
employees changing positions and external applicants) are required to participate in the
mandatory COVID-19 vaccination program. New VHA HCP employees must complete a
COVID-19 vaccination series prior to onboarding or have an approved accommodation
unless onboarding during a timeframe this requirement is waived by the Deputy Under
Secretary for Health.

(1) Announcements:

(a) Vacancies advertised using USA Staffing. HR Office staff must place language
explaining the COVID-19 vaccination requirement and the conditions of the COVID-19
Pandemic Expanded Telework Program in the additional information section of the JOA.

(b) Vacancies advertised outside of USA Staffing. HR Office staff must language
explaining the COVID-19 vaccination requirement in an appropriate place in the
advertisement.

(c) Vacancies not requiring advertisement. For vacancies filled without any type of
job announcement, HR Office staff will notify the selectee of the requirements via the
tentative offer letter.

(2) Job Offers

(a) Tentative job offers and firm job offers for HCP positions will contain language
informing applicants of the requirement for vaccination. The standardized language is
as follows:

i This is a tentative offer of employment. In order to receive a final

offer, you must provide appropriate documentation of your
COVID-19 vaccination or submit a request for legal
accommodation (i.e., medical, religious [or pregnancy]). By
accepting this tentative offer, you are acknowledging and
accepting your responsibility to provide proof of vaccination
status, and/or your request for a legally required accommodation.
If you are unable to obtain the COVID-19 vaccination due to a
legally covered accommodation, (i.e., medical, religious, or
pregnancy), I can provide additional information regarding how
you can request an accommodation. If you request a legally
required accommodation or had one previously approved, note
that an accommodation determination for this job offer will be
made on an individual basis since they do not automatically
transfer to a new position.

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January 27, 2022 VHA DIRECTIVE 1193.01
Appendix A

(b) Final job offers will not be made unless employees meet vaccination
requirements, have an approved accommodation, meet the critical hiring guidelines of
section 1, c(2) above, or are covered by a determination made by the Deputy Under
Secretary for Health on onboarding applicants with pending accommodations outside of
designated positions on the VA Form 10230a

(c) Final job offers will contain the required language for both internal and external
hires.

(3) USA Staffing System Reporting. USA Staffing system tags for applicants who
decline a position due to the COVID-19 Vaccination Requirement or fail to provide the
required documentation will be used.

(4) COVID-19 Vaccination Documentation. All new hires (internal and external) will
be required to complete tasks in USA Staffing and submit their COVID-19 vaccination
documentation and, if applicable, their intent to submit requests for accommodation to
the workplace requirement via VA Form 10230c, verbally, or in writing to Human
Resources.

(a) Documentation submitted by applicants will be required to conform to the

documentation requirements outlined in this directive.

(5) Accommodations for Applicants

(a) If an applicant requests an accommodation to the workplace requirement for

full COVID-19 vaccination, this request will be referred by Human Resources to the
appropriate Management Official/Supervisor and timely processing will be ensured.

(b) The Management Official/Supervisor will analyze the request for

accommodation utilizing VA Form 10230a and any additional information obtained
through the interactive process.

(c) The Management Official/supervisor will make a determination on the request

from the applicant, complete the appropriate paperwork, and notify Human Resources.

(d) Religious Accommodation Advisors, Local Reasonable Accommodation

Coordinators, Servicing Human Resources, and the Office of General Counsel are
available to assist Management Officials/supervisors with this analysis.

f. Health Professions Trainee (HPT) Compliance. Monitoring compliance and

documentation of HPT compliance with this notice is the responsibility of the Designated
Education Officer via the Trainee Qualifications and Credentials Verification Letter
(TQCVL) process. However, VHA may choose to offer vaccine to HPTs, and must
document vaccinations of HPTs using the same process used for other VHA HCPs.
HPT seeking an accommodation for medical, pregnancy, or religious reasons must be
evaluated using the processes set forth in this notice. The denial of an accommodation
request must be supported by the relevant facts and meet the applicable legal standard.
When an accommodation is denied, the HPT must receive their first (or, if a one-dose

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January 27, 2022 VHA DIRECTIVE 1193.01
Appendix A

series, only) dose within two weeks of the final determination to deny the
accommodation. If receiving a two-dose series, the HPT should receive the second
dose within six weeks of receiving the first dose. If an HPT received a first dose of a
two-dose series prior to seeking an accommodation, and the request for
accommodation is denied, the HPT must receive their second dose within two weeks of
the final determination to deny the accommodation (or within a week of the earliest day
by which they can receive their second dose), whichever is later.

g. Extended Leave of Absence. HCPs on an extended leave of absence (utilizing

annual leave, sick leave, donated annual leave, military leave, leave without pay, paid
parental leave, unpaid leave under the Family and Medical Leave Act, or leave of
absence due to receiving workers’ compensation) are required to submit documentation
establishing they are fully vaccinated (or request an accommodation) prior to returning
to VA duty. Documentation showing the volunteer, student, or intern in an HCP position
is fully vaccinated will be required prior to return to duty.

h. Detailed Employees. Employees on detail with VHA to HCP positions must

comply with this directive. Those employees should follow the procedures of this
directive to demonstrate compliance with the workplace requirement. VHA employees in
HCP positions on detail to positions not covered by this directive must provide
documentation establishing they are fully vaccinated (or request an accommodation)
prior to returning to VA duty in an HCP position and complete the electronic submission
process or VA Form 10230c within 14 days of entrance on duty. VHA HCPs on detail at
VA from non-Federal entities via assignment through Intergovernmental Personnel Act
(IPA) agreements will be required to follow the VHA procedures outlined in this notice to
comply with the vaccination requirement.

i. COVID-19 Vaccination Form. The VA Form 10230c is available at:

https://vaww.va.gov/vaforms/ and https://www.va.gov/find-forms/.

NOTE: The first link is an internal VA website that is not available to the public. To
access the form, type VA Form 10230 into the search bar.

3. ACCOMMODATIONS. VHA HCP may request an accommodation to being fully

vaccinated only for medical, religious, or pregnancy related reasons as prescribed in
this directive. In such cases, VHA HCPs should make the request in accordance
with the options above. The confidential nature of Personally Identifiable Information
(PII) and Protected Health Information (PHI) must be protected as required by
statute, regulation, and VA and VHA policies.

a. Types of Accommodations:

(1) Medical Accommodation. VHA HCP who decline to receive the COVID-19
vaccine because of a medical condition should complete the required information in the
designated VA system for electronic submission (or submit a completed VA Form
10230c), requesting an accommodation. The submission will be used to notify the
employee’s supervisor to initiate the reasonable accommodation process. If the request

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January 27, 2022 VHA DIRECTIVE 1193.01
Appendix A

for reasonable accommodation is denied, the employee is required to be fully

vaccinated as outlined below.

(2) Title VII Accommodations (Religious or Pregnancy). VHA HCPs who decline to
receive the COVID-19 vaccine because of a deeply held religious belief, practice, or
observance or for pregnancy related reasons should complete the required information
in the designated VA system for electronic submission (or submit a completed VA Form
10230c), requesting an accommodation. The submission will be used to notify the
employee’s supervisor to initiate the reasonable accommodation process. If the request
for reasonable accommodation is denied, the employee is required to be fully
vaccinated as outlined below.

b. Process

(1) Requests will be analysed utilizing VA Form 10230a.

(2) Reassignment processes are in accordance with VA Notice 22-04, Processing

Reassignments as a Reasonable Accommodation Regarding the COVID-19 Vaccine
Mandate.

(3) Decisions will be documented using the appropriate VA Form 0857(f) or VA Form
0857 (g) for medical accommodations or VA Form 10230b for Title VII Accommodations
(Religious or Pregnancy).

c. Denial of an Accommodation. The denial of a reasonable accommodation must be

supported by the relevant facts and meet the applicable legal standards. When an
accommodation is denied, the employee must receive their first (or, if a one-dose
series, only) dose within fourteen calendar days of the final determination to deny the
accommodation. If receiving a two-dose series, the employee should receive the
second dose within six weeks of receiving the first dose. If an employee received a first
dose of a two-dose series prior to seeking an accommodation, and the request for
accommodation is denied, the employee must receive their second dose within fourteen
days of the final determination to deny the accommodation (or within a week of the
earliest day by which they can receive their second dose), whichever is later.

4. DOCUMENTATION

a. Vaccination Performed by VHA. When VHA HCP is vaccinated in VHA Employee

Occupational Health (EOH), the person administering the vaccine, EOH staff or
designee, must document the vaccination in accordance with VA Handbook 5019,
Employee Occupational Health Service, , or as directed by VHA’s Office of Employee
Occupational Health. The VHA HCP must complete the required information in the
designated VA system for electronic submission (or VA Form 10230c). Acceptable and
complete documentation verifying vaccination (with information on the type of vaccine
administered, date(s) of administration, and name of health care professional(s) or clinic
site(s) administering the vaccine(s)) must also be delivered to the supervisor in the
designated electronic system or on the accompanying VA Form 10230c as applicable in
the requirements. In lieu of submitting proof of vaccination, an employee may voluntarily

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January 27, 2022 VHA DIRECTIVE 1193.01
Appendix A

elect to sign a release of information form (VA Form 10-5345) for VHA EOH to release
the information to the supervisor, including electronically using LEAF or other VA
information system, insofar as the vaccination information is available from VHA EOH.
The information released to the supervisor is limited to the information required to verify
receipt of the required COVID-19 vaccine doses.

b. Vaccination Performed by Other Providers. When the VHA HCP is vaccinated

outside of VHA EOH, the employee must complete required information in the
designated VA system for electronic submission (or VA Form 10230c). Acceptable and
complete documentation verifying vaccination (with information on type of vaccine
administered, number of doses received, date of administration, and name of health
care professional(s) or clinic site(s) administering vaccine) must also be delivered to the
supervisor in the designated electronic system or with the accompanying VA Form
10230c. Veteran employees vaccinated through primary care or other providers may
also authorize the release of vaccination information or provide a copy of the
vaccination documentation from their own records.

NOTE: VA medical facility EOH staff may not identify individuals according to their
vaccination status or otherwise indicate whether an individual has been vaccinated
unless that individual has provided a qualifying authorization to EOH permitting the
disclosure on VA Form 10-5345, Request for and Authorization to Release Health
Information. Questions should be referred to the local Privacy Office.

5. SAFETY PROTOCOLS FOR VHA HCPs NOT FULLY VACCINATED.

a. VHA HCP who have requested an accommodation to the COVID-19 vaccination

requirement or have an approved accommodation to the COVID-19 vaccination
requirement must wear a face mask while in any VA facility, including both clinical and
non-clinical areas. In addition, unvaccinated VHA HCPs are required to wear a face
mask during performance of their assigned duties and responsibilities, as outlined in
VHA policy.

b. The face mask must be worn until the individual is considered fully vaccinated for
COVID-19 and completes the information in the designated VA system for electronic
submission (or VA Form 10230c). Face masks should be worn as outlined in local and
national policies, collective bargaining agreements and memoranda of understanding
with labor unions. Face masks will be made available and distributed per local policies.
A face mask must be replaced when it becomes wet, visibly soiled, torn, or damaged.
Alternatives to face masks may be considered in limited situations, such as when an
employee is unable to wear a face mask and is approved for a reasonable
accommodation due to a qualifying disability or for pregnancy or religious reasons.
Fitted N95 respirators or other respirators are not required by this policy, but they
should be used when appropriate to task (e.g., when caring for a patient on airborne
infection isolation precautions); if N95 or higher respirators are used, they also serve the
purpose of being considered a face mask for this notice. Employees that require mask
alternatives based on a medical condition can request a reasonable accommodation
through their supervisor or contact their RA Coordinator.

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January 27, 2022 VHA DIRECTIVE 1193.01
Appendix A

NOTE: Local policy and memoranda of understanding with labor unions may require
different or more stringent guidelines, for example, that all individuals wear a face mask,
regardless of vaccination status, if a risk of transmission of SARS COV-2 exists.

c. VHA HCP may remove their face mask only in accordance with VA and VHA
masking guidance.

d. VHA HCP will submit to weekly COVID-19 testing.

e. VHA HCP will physically distance, maintaining 6 feet between themselves and
others.

f. VHA HCP will observe Government-wide travel restrictions for not fully vaccinated
employees.

g. VHA HCP will adhere to all other mitigation and safety strategies deemed
necessary and appropriate for the circumstances.

6. VHA HEALTH CARE PERSONNEL IN VIOLATION OF THIS DIRECTIVE

a. VHA HCP will be in violation of this directive if they are not fully vaccinated by
applicable deadlines or have not submitted the required information.

(1) Prior to the publication of this directive, information must have been submitted in
the designated VA system for electronic submission or via VA Form 10230.

(2) After the publication date of this directive, information must be submitted in the
designated VA system for electronic submission or via VA Form 10230c.

b. VHA HCP are required to provide the required documentation in a. which must
include:

(1) Documentation showing receipt of a complete COVID-19 vaccine series; or

(2) Documentation requesting an accommodation to being fully vaccinated.

c. At the time a request for accommodation from an HCP is denied, an employee is

considered non-compliant if vaccination is not started within fourteen days from
notification of the denial.

NOTE: Acceptable documentation includes a signed record of immunization from a

health care provider or pharmacy, a copy of the COVID-19 Vaccination Record Card
(CDC Form MLS-319813_r, published on September 3, 2020), a copy of immunization
records from a public health or state immunization information systems, a copy of
medical records documenting the vaccination, or a copy of any other official
documentation containing all data points.

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January 27, 2022 VHA DIRECTIVE 1193.01
Appendix A

d. Accommodations. If a request for accommodation is denied and an employee

does not become vaccinated in accordance with this directive, they will be considered
non-compliant.

e. Masking. VHA HCPs who refuse or fail to wear a face mask as prescribed will be
considered non-compliant with this notice.

f. Compliance with Requirement. Compliance with this notice is a requirement. VHA

HCPs in violation of this notice may face disciplinary action up to and including removal
from Federal service.

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