October 13, 2021
Covid-19 Vaccination Confirmations & Sponsored Programs
We anticipate many sponsors will require the UW to confirm Covid-19 vaccination of employees working on sponsored programs.
September 30, 2021: FAR Council memo directs agencies that issue contracts under the FAR to incorporate a clause in their solicitations and contracts to implement guidance issued by the Safer Fed Workforce Task Force pursuant to E.O. 14042. There is a new FAR 52.223-99 clause, Ensuring Adequate COVID-19 Safety Protocols for Federal Contractors.
Each agency is issuing its own implementing memo and agencies are being encouraged to expand use of the FAR clause beyond what’s required.
As of 10.25.2021 NSF revised their Cooperative Agreement Financial and Administrative Terms and Conditions (CA-FATC) to implement Executive Order 14042.
- Executive Order 14042: on Ensuring Adequate COVID Safety Protocols for Federal Contractors
- Safer Federal Workforce FAQs
- Memorandum for FAR Clause Implementation
When OSP receives an award modification, certification form, or other indication that a prime award sponsor is requesting vaccination confirmation, OSP will set up an action in SAGE, assign an OSP Reviewer, and notify campus. Most can be approved based on the UW’s own processes in place meeting sponsor requirements.
If the sponsor is requesting an attestation or certification about project personnel’s vaccine status, OSP reviewers will reach out to the PI & department contact to request written confirmation that the requirement is met (such as an email) from the appropriate department Human Resources individual.
Do Not Send OSP:
- Copies of vaccination proof (e.g. C19 vaccine cards)
- Workday screenshots
- Workday attestation reports for the unit
- Individual vendor/supplier or subrecipient Declarations
Note: subrecipient confirmations are handled via the UW Procurement Office.
For the Entire UW, as an Awardee / Grant Recipient
In coordination with the Office of Research, Academic HR, and UWHR, OSP is handling requests from sponsors that require certifications on behalf of the entire UW. These are not project specific.
Vaccine Confirmation of Vendors and Subrecipients
Review more information from the UW Procurement Office.
Q1: New FAR clauses - what about subawards to an organization that is outside of WA state that might not have the same local requirements? And what if we have subaward members who are not vaccinated?
A1: When the FAR clause is included in our contract, we are required to flow-down the clause in outgoing subcontracts. Each subcontractor will need to determine if they can accept the modification. It may be difficult for subcontractors in jurisdictions that do not have similar requirements. The PI should be aware that this may trigger some changes on how that portion of the work gets done. Review Safer Federal Taskforce FAQs on the requirements imposed by inclusion of the FAR clause.
Q2: Which Workday Roles are allowed to verify?
A2: Those in the unit who are authorized to view vaccine status/exemption status in Workday are the appropriate HR staff. In most cases, this is the I-9 coordinator. After verifying statuses, the I-9 coordinator simply needs to email the PI that we meet sponsor requirements. If there is more than one department involved, there will need to be coordination by the lead PI/dept. to gather those statements from each department for their personnel working on the project.