Emergency Request Letter

December 14, 2021
William Bestani
Desk Officer
Office of Information and Regulatory Affairs
Office of Management and Budget
Washington, D.C. 20530
Subject: Emergency PRA Clearance Request, Vaccination Attestation Form
Dear Mr. Bestani:
The Office of the Comptroller of the Currency (OCC) hereby requests approval for a vaccine
medical exception form pursuant to the Office of Management and Budget's (OMB) Paperwork
Reduction Act (PRA) emergency processing procedures at 5 C.F.R. § 1320.13.
The President, by Executive order 13991 (January 20, 2021) established the Safer Federal
Workforce Task Force. The Taskforce was established to give the heads of federal agencies
ongoing guidance to keep their employees safe and their agencies operating during the
COVID-19 pandemic. The Taskforce issued guidance, in accordance with the President’s
Executive Order 14043 (September 9, 2021), requiring federal employees to be vaccinated
against COVID-19 by November 22, 2021 absent a legally required exception. The
Taskforce issued guidance regarding individuals who start their government service after
November 22, 2021, stating that those individuals should be fully vaccinated prior to their start
date, except in limited circumstances where an accommodation is legally required. The guidance
also provided that agencies should require documentation to prove vaccination status of those
individuals prior to the enter on-duty date. To determine whether individuals who have been
offered a position with the Office of the Comptroller of the Currency (OCC) are fully vaccinated
during the onboarding process and before their enter on-duty date, in compliance with the
Taskforce guidance, the OCC has developed a form in an online application (Appian vaccination
attestation form).

The Request form was developed, consistent with guidance issued by the Taskforce and the
U.S. Department of Treasury, to gather information from employees regarding their
vaccination status and proof of vaccination. The Appian vaccination attestation form will
also be used to collect information from prospective employees. In order to comply with the
Taskforce guidance, the information to be collected on the Appian vaccination attestation
form is needed prior to the time periods established under 5 C.F.R. Part 1320. Compliance
with the vaccination mandate and the Taskforce guidance is essential to protecting the health

and safety of the OCC’s workforce, which is essential to the OCC’s accomplishment of its
mission.
The OCC cannot reasonably comply with the normal clearance procedures because the use of
normal clearance procedures will prevent the OCC onboarding new employees and, at the
same time, obtaining information on the Appian vaccination attestation form that is needed to
comply with the timeframes Taskforce’s guidance issued pursuant to Executive Order.
The OCC has determined that: (1) the collection of information within the scope of this request is
needed prior to the expiration of time periods established under 5 C.F.R. § 1320.12; (2) this
collection of information is essential to the mission of the OCC; and (3) the OCC cannot
reasonably comply with the normal clearance procedures because an unanticipated event has
occurred and the use of normal clearance procedures is reasonably likely to prevent or disrupt the
collection of information.
This information collection may not be cleared through 5 C.F.R. § 1320.11, which covers only
collections of information contained in proposed rules. As noted in 5 C.F.R. § 1320.5(c)(1), the
OCC must clear the collection under 5 C.F.R. § 1320.10, which relates to information collections
not contained in proposed rules or current rules. There is insufficient time to obtain clearance
under 5 C.F.R. § 1320.10 as the collection is needed immediately. Therefore, the OCC is
requesting emergency clearance.
Sincerely,
Patrick T. Tierney
Patrick T. Tierney
Assistant Director, Bank Advisory
Office of the Comptroller of the Currency

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