Privacy and Civil Liberties Impact Assessment
 

Privacy and Civil Liberties Impact Assessment 

for 

Treasury’s Collection, Use, and Disclosure of
 

Employee/Onboarding Employees’ Vaccination Status and Proof of 

Vaccination Information
 

November 25, 2021 

Reviewing Official 

Ryan Law
 

Deputy Assistant Secretary
 

Office of Privacy, Transparency, and Records
 

Department of the Treasury
 
 

 

 

 

 

 

 

 

 

 

 

Introduction This Privacy and Civil Liberties Impact Assessment (PCLIA) covers the Department of 

the Treasury’s (“Treasury” or “the Department”) departmentwide collection, use, and disclosure of 

vaccination status information and proof of vaccination records submitted by employees and individuals 

who accepted positions with Treasury after the issuance of EO 14043, but will not onboard prior to 

November 22, 2021 (collectively “employee” unless distinction is required). Rather than using the 

standard Treasury PCLIA template, this PCLIA is presented in a modified “question and answer” (Q&A) 

format to directly address questions employees may have about Treasury’s collection, use, and disclosure 

of their vaccination information/records. 

What is a Privacy and Civil Liberties Impact Assessment (PCLIA)? 

Treasury uses PCLIAs to: 

- Identify privacy and civil liberties risks and methods to minimize those risks 

- Ensure that programs or information systems meet legal, regulatory, and policy requirements; and 

- Tell the public how Treasury protects PII when it is collected, shared, stored, transmitted, and 

used. 

I. Executive Order 14043 Requirements 

On September 9, 2021, President Biden signed Executive Order (EO) 14043, titled, “Requiring 

Coronavirus Disease 2019 Vaccination for Federal Employees.” The President determined that it was 

necessary for all Federal agencies to require COVID–19 vaccination for Federal employees covered 

by EO 14043. The purpose of this requirement was to promote the health and safety of the 

workforce and the efficiency of the civil service, subject only to such exceptions required by law. 

By what date are Treasury employees required to comply with this requirement? 

EO 14043 requires Federal employees to be fully vaccinated by November 22, 2021. 

Which vaccines meet the EO 14043 requirements? 

As of November 24, 2021, the following has been approved by the U.S. Food and Drug Administration 

(FDA): Pfizer/BioNTech. 

As of November 24, 2021, the following vaccines have been authorized for emergency use by the FDA: 

Moderna and Johnson & Johnson/Janssen. 

As of November 24, 2021, the following vaccine has been authorized for emergency use by World Health 

Organization (WHO): AstraZeneca. 

What does “fully vaccinated” mean? 

Employees are fully vaccinated for COVID-19 two weeks after they receive the requisite number of doses 

of a COVID-19 vaccine approved or authorized for emergency use by the FDA or a vaccine that has been 

listed for emergency use by the WHO. 

What are the requisite number of doses for each vaccine? 

The following are two-dose vaccines: Pfizer-BioNTech, Moderna, and AstraZeneca/Oxford. An 

employee achieves full vaccination two weeks after the second shot of these vaccines. 

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The following is a one-dose vaccine: Johnson and Johnson (J&J)/Janssen. An employee achieves full 

vaccination two weeks after the first (and only) dose of this vaccine. 

By what date must an employee receive their last dose of each vaccine? 

Employees must receive the last dose (the only dose if J&J/Janssen) of their vaccine no later than 

November 8, 2021 to meet the November 22, 2021 deadline. 

II. Scope of the vaccination status/proof requirement 

Does the vaccination status/proof requirement apply to Federal employees who are not 

reporting to the worksite (e.g., are on maximum telework or working remotely)? 

All Federal employees covered by EO 14043, including those who are currently on maximum telework or 

working remotely (not reporting to the worksite) are required to be fully vaccinated and provide 

documentation proving vaccination by November 22, 2021. 

How do the vaccination/proof requirements apply to individuals who accepted positions with Treasury 

after the issuance of EO 14043 if they will not onboard prior to November 22, 2021? 

Treasury requires that individuals who start their government service prior to November 22, 2021 must be 

fully vaccinated by November 22, 2021, except in limited circumstances where an accommodation is 

legally required or a mission-critical hiring need can be shown. 

If a Treasury bureau or office establishes a mission-critical hiring need to onboard new staff who 

cannot be fully vaccinated by November 22, 2021, how long will new hires have to submit their proof of 

full vaccination? 

If a Treasury bureau or office has an urgent, mission-critical hiring need to onboard new staff who cannot 

be fully vaccinated by November 22, 2021, the agency head may delay the vaccination requirement—in 

the case of such limited delays, Treasury will require new hires to be fully vaccinated within 60 days of 

their start date and to follow safety protocols for not fully vaccinated individuals until they are fully 

vaccinated. 

Please refer to Frequently Asked Questions, Vaccination Requirement for Federal Employees for 

additional guidance. 

III. Collection of vaccination information/proof of vaccination 

Are there any restrictions on what vaccination information/proof of vaccination information Treasury 

may collect? 

The Privacy Act requires “each agency that maintains a system of records [to] maintain in its records only 

such information about an individual as is relevant and necessary to accomplish a purpose of the agency 

required to be accomplished by statute or by executive order of the President.” 5 U.S.C. § 552a (e)(1). 

Treasury is only collecting vaccination information/proof of vaccination information allowed by EO 

14043. 

Are employees required to submit documentation to prove that they are fully vaccinated? 

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By November 22, 2021, employees are required to submit documentation to prove that they are fully 

vaccinated. 

What data fields must be present in documentation provided as proof of full vaccination? 

Acceptable proof of vaccination is any official documentation that includes the following data fields: 

- Employee full name (first, middle name (or initial), and last name),
 

- Type of vaccine administered (Pfizer/BioNTech, Moderna, Johnson and Johnson/Jansen, and 

AstraZeneca),
 

- Date(s) of administration, and 

- Name of the health care professional(s) or clinic site(s) administering the vaccine(s).
 

What types of official documentation are acceptable? 

By November 22, 2021, Employees must submit a copy of any one of the following documents 

containing the required information: 

- A record of immunization from a healthcare provider or pharmacy, 

- Center for Disease Control (CDC) COVID-19 Vaccination Record Card, 

- Medical records documenting the vaccination,
 

- Immunization records from a public health or state immunization information system, or
 

- Any other official documentation containing the required data points. 

Is a particular digital format required for uploading/proving vaccination status? 

Treasury employees may provide a digital copy of their vaccination record(s), including, for example, a 

digital photograph, scanned image, or PDF of such a record that clearly and legibly displays the required 

information. 

How can employees transfer paper records to digital format? 

Most individuals vaccinated in the United States received a paper CDC COVID-19 Vaccination Record 

Card. Alternatively, they may have received a paper record of immunization. Any record must include the 

required data points: type of vaccine, dates of administration, and name of the health care professional or 

clinic site that administered the dose(s). Employees should not alter the form but may redact (blacken out) 

other Personally Identifiable Information or medical information displayed on it that is not one of the 

three required data fields (for example, employees may redact their social security number, patient 

identification number, or date of birth). 

Employees may be able to digitize a copy of their paper proof of vaccination by: 

- Using an office scanner or multi-function copier (MFC) with scanning capability. When using a 

shared scanner/MFC, employees should be sure to take appropriate steps to safeguard their 

personal information. 

- Taking a picture of the document using a government-issued smart phone or tablet and emailing it 

to your official email address. 

- Taking a picture of the document using a web camera attached to/built into a government-issued 

computer. 

- Using a personal device to scan/take a picture of the document and securely email it to their 

government-issued device. 

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Please refer to Frequently Asked Questions, Vaccination Requirement for Federal Employees for 

additional guidance. 

IV. Ensuring authenticity of proof of vaccination documentation 

How will Treasury ensure the authenticity of the documentation provided? 

On the Human Resources Connect (HRConnect) website where the data is collected, employees are 

required to attest that they understand that a knowing and willful false statement in information provided 

to prove vaccination can be punished by fine or imprisonment or both (18 U.S.C. 1001). Employees also 

must attest that they understand that making false statements on the form can lead to additional 

administrative action, including an adverse personnel action up to and including removal from their 

position. The documents submitted will also be reviewed by a panel of representatives from the relevant 

bureau or office. 

If a Treasury employee already provided information regarding their vaccination status (e.g., in 

HRConnect or via a bureau process), is anything else required? 

Fully vaccinated Treasury employees who already provided their vaccination type and the date of last 

dose required (depending on the vaccine received) prior to the issuance of EO 14043 are only required to 

provide documentation supporting the information provided earlier. These employees must also ensure 

that their information remains current (e.g., if they get a booster or other updates are required). 

Employees who visited the HRConnect vaccination site prior to the issuance of EO 14043 and stated they 

were unvaccinated or declined to answer the questions must complete all required fields and provide the 

required documentation. 

All employees are required to keep their information on the site current. 

If a Treasury employee already attested to their vaccination status earlier (prior to the vaccine/proof of 

vaccination mandate), why do they need to provide documentation and attestation again? 

Proof of vaccination status is now required even if an employee previously attested to their vaccination 

status within HRConnect or via a bureau-required process. EO 14043 also requires that Treasury 

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

The Attestation (which does not require certification under penalty of perjury) is no longer sufficient to 

meet the vaccination status reporting requirement. On the HRConnect website where the data is 

collected, employees are now (but were not previously) required to attest that they understand that a 

knowing and willful false statement in information provided to prove vaccination can be punished by fine 

or imprisonment or both (18 U.S.C. 1001). Employees also must attest that they understand that making 

false statements on the form can lead to additional administrative action, including an adverse personnel 

action up to and including removal from their position. The documents submitted will also be reviewed 

by a panel of representatives from the relevant bureau or office. 

V. Limiting the personally identifiable information employees submit 

Is one of the required types of official documentation preferred over others? 

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All forms of official documentation are acceptable if they contain the required data fields. If, however, 

employees have more than one of these documents available, they should provide the document that 

includes the least amount of personally identifiable information in addition to the three required data 

fields. 

If an employee only has access to documentation that includes other personally identifiable/medical 

information, in addition to the required data fields, what should the employee do? 

The employee may redact/blacken out with a marker any additional data fields before copying/submitting 

the document. 

VI. Legal authority and issues 

On what legal authority does Treasury rely to collect vaccination status information and proof of 

vaccination records? 

On September 9, 2021, the President issued EO 14043, Requiring Coronavirus Disease 2019 Vaccination 

for Federal Employees. This EO requires COVID-19 vaccination for Federal executive branch employees 

(as defined in 5 U.S.C. 2105), except in limited circumstances where a reasonable accommodation is 

legally required. 

a. Title II of Genetic Information Nondiscrimination Act (GINA) 

Is Title II of GINA implicated when an employer requires employees to provide proof that they have 

received a COVID-19 vaccination? 

Requiring employees to provide proof that they received a COVID-19 vaccination does not implicate 

Title II of GINA, because it does not involve the use of genetic information to make employment 

decisions, or the acquisition or disclosure of “genetic information” as defined by the statute. 

Under GINA, can agencies ask employees if their family members were vaccinated 

GINA does prohibit employers from asking employees medical questions about family members. 

Does inquiring about an employee’s vaccine status for a valid business purpose violate discrimination 

laws? 

Inquiring about an employee’s vaccine status for business purposes does not likely implicate 

discriminatory issues. To avoid implicating the Rehabilitation Act of 1973 and other issues, EEOC 

recommends that supervisors avoid asking further questions that elaborate on why the employee chose not 

to receive the vaccine, because such questions could elicit information about health or disability. 

Under the Rehabilitation Act of 1973, Title VII, and other Federal employment nondiscrimination 

laws, may an employer require all employees physically entering the workplace to be vaccinated for 

COVID-19? 

According to the Rehabilitation Act of 1973 and other EEO laws (EEOC Technical Assistance) guidance, 

Federal EEO laws do not prevent an employer from requiring all employees physically entering the 

workplace to be vaccinated for COVID-19. Employers are, however, subject to the reasonable 

accommodation provisions of Title VII and the Rehabilitation Act of 1973 and other EEO considerations. 

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Are there any EEO impediments to agencies requiring employees to be vaccinated before returning to 

the workplace? 

After the White House required vaccines for all Federal employees, the EEOC issued guidance that 

allows employers to require employees, even outside of certain essential and/or healthcare related 

occupations, to get vaccinated against COVID-19 before returning to the workplace. 

b. The Rehabilitation Act of 1973 

Under the Rehabilitation Act of 1973, may an employer require a COVID-19 vaccination for all 

employees entering the workplace, even though it knows that some employees may be unable to get a 

vaccine because of a disability? 

Under the Rehabilitation Act of 1973, Treasury may require an individual with a disability to meet a 

qualification standard applied to all employees, such as a safety-related standard requiring COVID-19 

vaccination if the standard is job-related and consistent with business necessity. If a particular employee 

cannot meet such a safety-related qualification standard because of a disability, Treasury will not require 

compliance for that employee unless evidence exists showing that the individual would pose a “direct 

threat” to the health or safety of the employee or others in the workplace. 

Under the Rehabilitation Act of 1973, if an agency requires COVID-19 vaccinations for employees 

physically entering the workplace, how should an employee who does not get a COVID-19 vaccination 

because of a disability inform the employer? 

An employee with a disability who does not get vaccinated for COVID-19 because of a disability must let 

Treasury know that he/she needs an exemption from the vaccination requirement, or a workplace 

modification known as a reasonable accommodation. 

Are there any “magic words” an employee must use to request an accommodation? 

When requesting a reasonable accommodation, an individual does not need to mention the Rehabilitation 

Act of 1973 or use the term “reasonable accommodation.” 

How does the reasonable accommodations request process work for accommodations that will be 

required only after the employee returns to work in a Treasury facility? 

Treasury may inform the workforce that employees with disabilities may request accommodations in 

advance that they believe they may need when the workplace re-opens. If advance requests are received, 

Treasury may begin the "interactive process" – the discussion between the employer and employee 

focused on whether the impairment is a disability and the reasons that an accommodation is needed. If an 

employee chooses not to request accommodation in advance, and instead requests it at a later time, 

Treasury must still consider the request at that time. 

Is medical documentation required to support a request for an accommodation? 

Medical documentation is not required to request an accommodation; however, a determination may be 

made during the accommodations process that it is necessary to obtain supporting medical documentation 

regarding the employee’s disability. 

Are there any resources available to assist employers and employees in their discussion about 

accommodations? 

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Employees may find it helpful to educate themselves on the Job Accommodation Network (JAN) website 

as a resource for different types of accommodations. Treasury also may consult applicable Occupational 

Safety and Health Administration (OSHA) COVID-specific resources. 

c.	 Title VII of the Civil Rights Act: Sincerely Held Religious Belief, Practice or 

Observance 

Can an employee indicate that he or she is unable to receive a COVID-19 vaccination because of a 

sincerely held religious belief, practice, or observance? 

Under Title VII, employees may seek an exception to the vaccination requirement based on “a sincerely 

held religious belief, practice, or observance.” If a sincerely held religious belief, practice, or observance 

is submitted, an employer typically provides an accommodation, unless providing the accommodation 

would pose an “undue hardship.” 

What is an “undue hardship”? 

Courts have defined “undue hardship” under Title VII as having more than a de minimis cost or burden 

on the employer. 

VII. Adverse actions and employee rights 

Will Treasury pursue any adverse action against an employee if they refuse to be vaccinated and/or 

provide proof of vaccination? 

In the absence of a legally-required accommodation, if an employee refuses to be vaccinated and/or 

provide proof of vaccination, Treasury will pursue disciplinary measures, up to and including removal 

from Federal service. Employees covered by EO 14043 who fail to comply with a requirement to be fully 

vaccinated or provide proof of vaccination and have neither received an exception nor have an exception 

request under consideration, are in violation of a lawful order. Employees who violate lawful orders are 

subject to discipline, up to and including termination or removal. 

Will Treasury pursue any adverse action against an employee if the employee submits false proof of 

vaccination documentation under penalty of perjury? 

If an employee submits false proof of vaccination documentation under penalty of perjury, Treasury will 

pursue disciplinary measures, up to and including removal from Federal service. Treasury may also take 

additional action as allowed by law. 

What rights will an employee have if Treasury pursues adverse action? 

In pursuing any adverse action, Treasury will provide the required procedural rights to an employee and 

follow normal processes, including any Treasury policies or collective bargaining agreement requirements 

concerning disciplinary matters. Employees will not be placed on administrative leave while pursuing an 

adverse action for refusal to be vaccinated but will be required to follow safety protocols for employees 

who are not fully vaccinated when reporting to agency worksites. 

VIII. Use of Vaccination Status and Proof of Vaccination Status Information 

What information should not be included when tracking vaccine status within the agency? 

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It would be best not to include on the list any personally identifiable information (PII) that is not 

necessary for tracking; for example, when an employee declines a vaccination for health reasons, the list 

should not identify or describe the health condition or other personal information provided by the 

employee. 

How will Treasury maintain and ensure the confidentiality of these vaccination status tracking lists? 

Treasury will maintain tracking lists in secure administrative or management files only accessible to 

Treasury Personnel who have a “need to know” that information to perform their official Treasury duties. 

IX. Compliance with privacy, security, records management requirements 

What laws govern Treasury’s collection, use, and disclosure of vaccination status records? 

When collecting, using, and disclosing vaccination status and proof of vaccination status information, 

Treasury is required to comply with all applicable Federal laws, including requirements under the Privacy 

Act of 1974 and the Rehabilitation Act of 1973. 

How long will Treasury maintain vaccination status and proof of vaccination status information? 

Treasury will maintain vaccination status and proof of vaccination status information in accordance with 

National Archives and Records Administration (NARA) General Records Schedule 2.7 Item 040, 

Employee Health and Safety Records. 

Does the Paperwork Reduction Act (PRA) apply to Treasury’s collection of vaccination status and 

proof of vaccination status information collected from Federal employees? 

The PRA does not apply to the collection of information from Federal employees. 

What privacy requirements apply to the collection of vaccination status and proof of vaccination status 

information? 

Treasury is required to draft a system of records notice (SORN), a Privacy Act statement (PAS), and a 

Privacy and Civil Liberties Impact Assessment (PCLIA). 

On what Privacy Act system of records notice does Treasury rely to collect vaccination status 

and proof of vaccination status information? 

Department of the Treasury System of Records Notice .020 - Health Screening and Contact 

Tracing Records. 86 Fed.Reg. 35, at 11381 (Feb. 24, 2021). 

On what Privacy Act system of records notice does Treasury rely to collect information related to 

disabilities and reasonable accommodations requested or granted under the Rehabilitation Act, the 

Religious Freedom Restoration Act of 1993 and/or Title VII of the Civil Rights Act of 1964? 

Treasury maintains .016 - Reasonable Accommodations Records System of Records, which allows 

Treasury, its bureaus, and offices to collect and maintain records on: 

“Applicants for employment who have disabilities; Individuals who seek accommodations 

to perform the essential functions of their job; Individuals with disabilities to facilitate 

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their participation in a Treasury program or activity, including their attendance at a 

meeting, training, conference or other Treasury-sponsored event at either a Treasury 

facility or outside Treasury or Treasury-sponsored event by Treasury; applicants for 

employment who have disabilities; employees who seek accommodations to allow them to 

perform the essential functions of their job; and employees with disabilities who request or 

receive reasonable accommodation as required by the Department as the Rehabilitation 

Act of 1973 and the Americans with Disabilities Act, as amended by the Americans with 

Disabilities Amendment Act of 2008 (ADAAA); individuals who receive accommodations 

under the Family Medical Leave Act, and individuals who receive accommodations under 

the Religious Freedom Restoration Act of 1993 and/or Title VII of the Civil Rights Act of 

1964 require.” 

When Treasury collects vaccination status and proof of vaccination status information in HRConnect, 

will employees receive a Privacy Act Statement (PAS) as required by the Privacy Act? 

At all points (and places) where Treasury, its bureaus, and offices collect vaccination status and proof of 

vaccination status information, Treasury provides employees with a PAS. 

What is in the PAS? 

The actual content of the Departmental PAS, located at the points at which Treasury collects vaccination 

status and proof of vaccination status information, is as follows: 

Privacy Act Statement 

Authority: Solicitation of this information is authorized by Occupational Safety and Health Act 

(OSHA) of 1970, Public Law 91-596, Section 19(a) (29 U.S.C. 668(a)); 5 U.S.C. 301; Medical 

Examinations for Fitness for Duty Requirements, including 5 CFR part 339; Executive Order 

12196, 5 U.S.C. 7902(d); 29 U.S.C. 668, 29 CFR part 1904, 29 CFR 1910.1020, 29 CFR 

1960.66; Executive Order 14042, Ensuring Adequate COVID Safety Protocols for Federal 

Contractors (September 09, 2021); Executive Order 14043, Requiring Coronavirus Disease 2019 

Vaccination for Federal Employees (September 09, 2021); Executive Order 12107, Relating to 

the Civil Service Commission and labor-management in the Federal service (December 28, 

1978); Executive Order 12564, Toward a Drug-Free Federal Workforce (September 15, 1986); 

and 5 U.S.C. chapters 11, 33, 63, and 79. 

Purpose: The Department of the Treasury (“Treasury” or the “Department”) is collecting this 

information to promote the safety of Federal buildings and the Federal workforce consistent with 

the above-referenced authorities, the COVID-19 Workplace Safety: Agency Model Safety 

Principles established by the Safer Federal Workforce Task Force, and guidance from Centers for 

Disease Control and Prevention and the Occupational Safety and Health Administration. 

Routine Uses: While the information requested on this form is intended to be used primarily for 

internal purposes, in certain circumstances Treasury may be required to disclose this information 

externally in accordance with the routine uses outlined in .020, Department of the Treasury -

Health Screening and Contact Tracing Records, available at 86 FR 11381 (Feb. 24, 2021). 

Disclosure: Providing your vaccination status information (including vaccination type, date of 

last vaccination, and proof of vaccination) is mandatory. Your access to Treasury buildings and 

or managed properties could be denied for failure to provide the required information. 

Employees who refuse to provide proof of vaccination by the required dates may also be 

terminated from employment. 

Are Federal agencies required to apply any special protections to vaccination status and proof of 

vaccination status information? 

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Vaccination status and proof of vaccination status information constitute “Confidential Medical 

Information” (CMI) as defined in the Rehabilitation Act of 1973. There are special requirements that 

apply to CMI (see next question). 

Are there any special protections applied to information employees provide to the Office of Civil Rights 

and Diversity (OCRD) or the Bureau’s Reasonable Accommodation Coordinator in support of a 

request for a reasonable accommodation/exception to vaccination requirements due to a disability? 

Information provided in support of a reasonable accommodation request for an accommodation due to a 

disability covered by the Rehabilitation Act of 1973 is also treated as CMI. 

How are Treasury supervisors reminded of their responsibilities when they need to access and use CMI 

for official Treasury purposes? 

There is a warning banner that will appear on the page where supervisors access information limited to 

vaccination status information and records (no records in support of requests for exceptions to the 

vaccination requirements because of disabilities or religious beliefs, observances, or practices (which are 

stored at OCRD or at the Bureau Reasonable Accommodation Office only and are not shared with 

supervisors)). See warning banner language below: 

“The information on this page constitutes Confidential Medical Information (CMI) 

that is restricted under the Americans With Disabilities Act. CMI: (1) must be kept 

confidential whether or not it relates to a disability; (2) must be kept separate from other 

personnel records (but may be maintained with the employee’s other medical records); 

and (3) may not be maintained in folders or on other recording media (including 

notepads, laptops, or other devices) where it can be accessed or viewed by others who 

lack a need to know. Supervisors may use CMI to report to appropriate agency officials 

so the agency can take appropriate actions and ensure compliance with guidance and 

safety protocols issued by the Center for Disease Control (CDC) and other public health 

authorities and to implement relevant federal law, regulations, and executive 

orders. Supervisors must ensure prior to disclosure that internal recipients of CMI have a 

need to know. All external disclosures must comply with the Privacy Act of 1974, 

including the routine uses in Treasury .020 - Health Screening and Contact Tracing 

Records. For all internal and external disclosures, care must be taken to omit information 

that may identify the individuals about whom the CMI is maintained where identification 

is not required. Reasonable effort must be made to limit the number of people who know 

the name of the employee associated with the CMI. Unauthorized or improper access 

and/or use of the vaccination records maintained in this system is prohibited and may 

result in civil and criminal penalties pursuant to 5 U.S.C. § 552a(i)(1)-(3).” 

Are there any special protections applied to information provided to OCRD or the Bureau Reasonable 

Accommodation Coordinator in support of a request for an exception to vaccination requirements 

because of religious beliefs, observances, or practices? 

Under the Privacy Act, 5 USC Section 552a, Federal agencies typically cannot collect information from 

individuals about how they exercise their First Amendment rights, including how they exercise their right 

to religious freedom. An exception exists when the individual voluntarily provides the information to 

obtain a benefit or service from the government (or, in this case, an exception to a requirement). 

Information provided to OCRD or to the Bureau Reasonable Accommodation Coordinator in support of a 

request for an exception to vaccination requirements because of religious beliefs, observances, or 

practices under the Religious Freedom Restoration Act of 1993 and/or Title VII of the Civil Rights Act of 

1964 is protected under the security and privacy requirements in the Privacy Act. 

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________________________________ 

X. Ensuring the accuracy of vaccination information maintained 

How does Treasury maintain the accuracy of vaccination status information employees provide? 

Employees are required to keep their vaccination status information current (including providing updated 

supporting documentation), including any vaccination boosters received (so Treasury can continue to 

monitor compliance with evolving CDC guidance). 

Are there penalties for providing false information on the vaccination attestation form? 

Federal employees who make a false statement on the Certification of Vaccination form could be subject 

to an adverse personnel action, up to and including removal from their position. It is also a federal crime 

(18 U.S.C. § 1001) for anyone to provide false information on the form. Falsification could also affect 

continuing eligibility for access to classified information or for employment in a national security position 

under applicable adjudicative guidelines. 

Will Treasury take any adverse action against an employee without first giving them an opportunity to 

update their vaccination status information and documentation to meet the requirements? 

No adverse action will be taken against an employee without first giving them an opportunity to update 

their vaccination status information and documentation to reflect actual compliance with the 

requirements. 

Responsible Officials 

Approval Signature 

Ryan Law 

Deputy Assistant Secretary 

Privacy, Transparency, & Records 

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