Message from the Office of Academic Affiliations:
Good afternoon DEOs:
We have received several inquiries related to COVID vaccination attestation of HPTs and when such verification can be sought during the recruitment process. As with all issues related to the pandemic, the guidance related to this issue is continuing to be disseminated by the Office of Personnel Management (OPM) and the Office of the Chief Human Capital Officer (OCHCO).
We talked with the Office of General Counsel (OGC) about these issues and, similar to OAA, OGC is concerned that asking for vaccination status prior to an offer of employment might be considered a prohibited personnel practice. While the facts of each case are different, OAA is strongly advising the following:
1. Applicants should be informed through public materials and discussion during the interview process that COVID vaccination (or approved exception) is a requirement for VA employment, including those who are coming to VA as without compensation (WOC) and those whose compensation is covered by a disbursement agreement (DA).
2. Facilities should treat HPT applicants the same as staff applicants in VA and not ask for vaccination status prior to an initial offer of employment (i.e., the Match). This not only aligns with OAA’s current policy and process to determine immunization via the TQCVL, but also aligns with the approach of VA and OPM for new staff (see links below).
OAA strongly believes that HPT applicants are motivated to follow the VA requirements for employment and we do not anticipate significant problems in onboarding HPTs in VA due to the new vaccination requirements. Preliminary data shows that the vast majority of VA paid HPTs are fully compliant with the vaccination attestation in LEAF- we suspect that coding errors likely account for the few that are not yet in compliance.
OPM System of Records: https://www.govinfo.gov/content/pkg/FR-2021-12-01/pdf/2021-26086.pdf
OCHCO Bulletin: Applying Coronavirus Disease 2019 (COVID-19) Vaccination Requirements to New Hires – Executive Order 14043 – AMENDED
Erin L. Patel, Psy.D., ABPP | Acting Chief, Health Professions Education
Office of Academic Affiliations (14AA)
Veterans Health Administration | Department of Veterans Affairs
811 Vermont Avenue, NW | Washington, D.C. 20420
(202) 705-5209 (cell)