San Diego, CA - Feb 2021: Drive though Covid 19 vaccination site at Petco Park, a professional baseball stadium.

The Defense Department has set limits on the circumstances in which management may ask civilian employees about whether they have been vaccinated against the Coronavirus, saying that such questions may be asked “only if there is a business necessity for this information, as determined on a case-by-case basis.”

While the policy applies only at DoD, it is notable because that is the government’s largest agency and the guidance addresses a topic that has come to the forefront as increasing numbers of federal employees have been vaccinated.


DoD addressed the issue in the context of general policy on vaccination including granting of leave related to vaccinations (see related story). It said that supervisors “may ask employees about the time and location of the vaccination event” for that purpose, as well as for granting leave that is requested on grounds that the vaccination cause side effects.

But the guidance notes that vaccination “has not been established as a requirement through appropriate DoD processes for any DoD civilian occupation . . . Therefore, the information is not necessary for purposes of most employment decisions.”

“In particular, information about an employee’s vaccination status is not necessary for supervisors to make decisions about how and when employees will report to a workplace instead of telework,” it says. “Supervisors need to follow applicable force health protection guidance and implement appropriate workplace measures to protect all employees, assuming that not everyone will be vaccinated.”

“Only in very limited circumstances, such as determining how long an employee with a known or suspected exposure must temporarily remain out of the workplace or whether an employee may be exempted from certain force health protection requirements as authorized in applicable policy, would it be reasonably necessary to request an employee voluntarily provide information about the employee’s vaccination status,” it says.

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