Emergency Letter

November 19, 2021

Ms. Sharon Block
Acting Administrator
Office of Information and Regulatory Affairs
Office of Management and Budget
Eisenhower Executive Office Building
Washington, DC 20503
Dear Ms. Block:
Pursuant to Office of Management and Budget (OMB) procedures established at 5 C.F.R.
Part 1320, Controlling Paperwork Burdens on the Public, I request that the proposed Department
of Housing and Urban Development information collection covered by form HUD-1001,
“Request for a Medical Exception to the COVID-19 Vaccination Requirement,” be processed as
an emergency clearance request in accordance with 5 C.F.R. § 1320.13, Emergency Processing.
I have determined that this information must be collected prior to the time periods
established under Part 1320 of the regulations and that this information collection is essential to
implement health and safety measures requiring all civilian Federal employees be vaccinated as
mandated by Executive Order 14043 of September 9, 2021, Requiring Coronavirus Disease
2019 Vaccination for Federal Employees, and included within Safer Federal Workforce Task
Force Guidance which mandated all Federal employees be vaccinated by November 22, 2021.1
The only exception is for individuals who receive a legally required exception approved under
established agency processes. HUD is requesting an expedited approval of the medical
exception form to process these requests in accordance with EO 14043. Applying regular
Paperwork Reduction Act clearance procedures is likely to cause harm because of the threat of
COVID-19 exposure and transmission.
Because of the nature of the public health emergency and the urgent need for the
Department to meet the November 22, 2021, deadline that all Federal employees be vaccinated
except those approved under a medical or religious exemption, it is impracticable for HUD to
consult in advance with interested agencies and members of the public in order to minimize the
burden of the collection of information pursuant to 5 C.F.R. § 1320.13(c). Therefore, HUD
requests a 180-day emergency clearance to obtain the information required in form HUD-1001,
“Request for a Medical Exception to the COVID-19 Vaccination Requirement.” During the 1801

See generally Executive Order 13991: Protecting the Federal Workforce and Requiring Mask-Wearing (January
20, 2021). See also Executive Order 12196: Occupational Safety and Health Programs for Federal Employees, as
amended (February 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”).

www.hud.gov

espanol.hud.gov

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day emergency clearance period, HUD will work to establish a regular clearance submission. As
this request for approval concerns an urgent safety need, HUD is also seeking 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) prior to publication and implementation of this disclosure.
We would appreciate if you could please provide an approval/disapproval determination
of this request to collect information under an emergency clearance by close of business on
Monday, November 22, 2021.
Sincerely,

Lori A. Michalski
Chief Human Capital Officer
Enclosures