Justification Statement - USPSC Medical Exception Form _signed

November 8, 2021
MEMORANDUM
TO:

Michael McManus, USAID Desk Officer Office of Information and
Regulatory Affairs (OIRA)
Office of Management and Budget (OMB)

FROM:

Heather Bomans
Senior Operations Management Coordinator, Bureau for Management, Critical
Coordination Structure (M/CCS) at the U.S. Agency for International
Development (USAID)

SUBJECT:

Justification for Emergency Processing

To protect the health and safety of the Federal workforce, Executive Order 14042 (Ensuring
Adequate COVID Safety Protocols for Federal Contractors) requires all U.S. Personal Services
Contractors (USPSC) to be fully vaccinated by January 18, 2022, other than in limited
circumstances where the law requires an accommodation. USAID is implementing this
vaccination requirement for its workforce and reviewing contractors requests for religious or
medical exceptions, or delays to the requirement because of a temporary condition or medical
circumstance. Determining whether an exception or delay is legally required includes
consideration of factors such as the basis for the claim; the nature of the contractor’s job
responsibilities; and the reasonably foreseeable effects on the agency’s operations, including
protecting other agency employees and the public from COVID-19.
For USAID USPSCs who believe they are not able to get vaccinated because of a qualifying
medical condition and submit an exception request, USAID must evaluate the medical conditions
on a case-by-case basis. Since an evaluation requires the collection of medical information in
order to help determine whether the contractor is entitled to an exception or delay, USAID
proposes to utilize a medical information collection form, based directly on the template form
provided by the Safer Federal Workforce Task Force and with no material changes, to ensure
USAID has the most accurate and current information on requesting contractors’ medical
conditions. The form will require the contractor to obtain information on their medical condition
from their medical provider, including the signature of their provider, in order to move forward
with review of their medical exception request. As such, USAID requests OMB approval to
conduct this information collection with USAID USPSCs requesting medical exceptions to the

COVID-19 vaccination requirement. The information obtained in these forms would inform who
is granted a legally-required medical exception to the federal vaccine mandate.
The Paperwork Reduction Act (PRA) of 1995 requires that agencies obtain OMB approval
before requesting most types of information from the public ("information collections" include
forms, interviews, and record keeping). USAID seeks emergency approval of information
collection associated with administering this form and requests OIRA approval to not publish a
Federal Register notice in relation to this form. USAID cannot reasonably comply with the
normal clearance procedures under the PRA because complying would delay the Agency's
efforts to comply with the guidance issued by the Safer Federal Workforce Task Force and the
deviation contract clauses issued to implement that guidance (FAR 52.223-99, DFARS
252.223-7999, etc.) by the January 18, 2022 deadline. Our request meets the standard for
emergency processing as the Agency needs adequate medical information and time to process
legally-required medical exceptions to the federal vaccine requirement, and USPSCs must
receive their last dose of their vaccine no later than January 4, 2022, to meet the January 18,
2022 deadline to be fully vaccinated. Additionally, the COVID-19 pandemic is an unanticipated
event with immediate risks to workforce lives, warranting emergency processing. These forms
are critical to USAID's compliance with the federal vaccination mandate and COVID-19
response efforts as we need contractors requesting medical exceptions to obtain verified medical
information from their health care provider(s) in order to adequately evaluate contractors for an
exception or delay. As such, we request expedited approval of this information collection.
Further, USAID respectfully requests that OIRA waive the requirement for publication of a
federal register notice for the proposed collection prescribed by 5 CFR § 1320.5(a)(1)(iv), in
accordance with the procedures for emergency processing set forth at 5 CFR § 1320.13(d).
Signed by:
signed by Heather
Heather Michelle Digitally
Michelle BOMANS (affiliate)
Date: 2021.11.08 09:31:07 -05'00'
BOMANS
(affiliate)
________________________

Heather Bomans
Senior Operations Management Coordinator
Bureau for Management, Critical Coordination Structure (M/CCS)
November 8, 2021