Emergency Request Letter

National Science Foundation
EMERGENCY PRA CLEARANCE REQUEST
November 10, 2021
Sharon Block, Acting Administrator
Office of Information and Regulatory Affairs
Office of Management and Budget
725 17th Street, NW
Washington, DC 20503
Dear Ms. Block:
Pursuant to Office of Management and Budget (OMB) procedures established under the Paperwork
Reduction Act (PRA), 5 C.F.R. Part 1320, the National Science Foundation (NSF) requests that two
proposed NSF information collection forms be processed as an Emergency Clearance Request in
accordance with 5 C.F.R. § 1320.13 (Emergency Processing).
The proposed NSF forms are entitled, respectively, “Request for a Medical Exception to the COVID19 Vaccination Requirement” and “Request for a Religious Exception to the COVID-19 Vaccination
Requirement.” They are based directly upon the information collection forms prescribed by the Safer
Federal Workforce Task Force for use by all Federal agencies. 1
I have determined that this information must be collected prior to the time periods established under
Part 1320, and that this information is essential to the proper implementation of health and safety
measures under current Centers for Disease Control and Prevention and Safer Federal Workforce
Task Force guidance. 2 Applying regular PRA clearance procedures is likely to cause harm because
of the threat of COVID-19 exposure and transmission, and could result in violations of Federal law
(e.g., title VII of the Civil Rights Act of 1964, Americans with Disabilities Act, and Rehabilitation
Act of 1973), for failure to timely identify and respond to individuals who may be entitled to
reasonable accommodation from mandatory Federal workplace vaccination requirements on medical
disability or religious grounds.
https://www.saferfederalworkforce.gov/downloads/DISABILITY%20REQUEST%20FORM%20%2020211004_510pm%20-%20MH508.pdf (medical exception, issued Oct. 4, 2021);
https://www.saferfederalworkforce.gov/downloads/RELIGIOUS%20REQUEST%20FORM_FINAL
%20REVIEW_20211003%2010.29%2011am.pdf (religious exception, updated Oct. 29, 2021).
1

2

See generally Executive Order 13991: Protecting the Federal Workforce and Requiring MaskWearing (Jan. 20, 2021); Executive Order 13994: Ensuring a Data-Driven Response to COVID-19
and Future High-Consequence Public Health Threats (Jan. 21, 2021); Executive Order 14043:
Requiring Coronavirus Disease 2019 Vaccination for Federal Employees (Sept. 21, 2021). See also
Executive Order 12196: Occupational Safety and Health Programs for Federal Employees, as
amended (Feb. 26, 1980) (“The head of each agency shall . . . [f]urnish to employees places and
conditions of employment that are free from recognized hazards that are causing or are likely to
cause death or serious physical harm”).

2415 Eisenhower Avenue | Alexandria, VA 22314

National Science Foundation

Moreover, I have determined that because of the nature of the public health emergency and the
urgent need for this collection, it is impracticable for NSF to consult in advance with interested
agencies and members of the public to minimize the burden of the collection of information pursuant
to 5 C.F.R. § 1320.13(c). NSF intends to consult with other agencies as appropriate through the
Safer Federal Workforce Task Force. NSF estimates that the information collection will entail
minimal public burden, as described in NSF’s Supporting Statement for these forms, since these
forms are primarily for use by NSF employees, who are not members of the public.
Therefore, NSF requests a 180-day emergency clearance to establish and utilize the two
information collection forms, based directly on the forms prescribed by the Task Force, to allow
individuals to seek medical or religious accommodation from Federal vaccination requirements at
NSF. During the 180-day approval, NSF will consult with the Task Force as appropriate to prepare a
regular clearance submission of this information collection request under normal PRA procedures in
anticipation of the expiration of the 180-day emergency period.
In addition, as this request for emergency approval concerns an urgent safety need, NSF also requests
OMB’s approval to waive the need for the Federal Register Notices otherwise required by 5 C.F.R.
§§ 1320.5(a)(1)(iv) and 1320.8(d)(1) before conducting or sponsoring the information collection
discussed above.
For the above reasons, NSF respectfully request that OMB approve this request to collect information
under an emergency clearance by or before close of business on November 20, 2021.
Sincerely,
Digitally signed by

WONZIE L
WONZIE L GARDNER JR
2021.11.10
GARDNER JR Date:
09:08:10 -05'00'
Wonzie L. Gardner, Jr.
Office Head and Chief Human Capital Officer
Office of Information and Resource Management
National Science Foundation
Office: (703) 292-8100
[email protected]

Enclosures

2415 Eisenhower Avenue | Alexandria, VA 22314