The Corps Network – Statement on Corps Vaccination Policies

On September 9, 2021, the Biden Administration signed an executive order detailing the applicability of safety protocols for COVID-19 for federal contractors. See: Executive Order on Ensuring Adequate COVID Safety Protocols for Federal Contractors. The Corps Network acknowledges that this potentially expanded scope of vaccination requirements, testing, and/or disclosure may impact the work of its 130+ member Service and Conservation Corps, particularly those projects occurring on federal properties.

The Executive Order does not apply to:

  1. grants;
  2. contracts, contract-like instruments, or agreements with Indian Tribes under the Indian Self-Determination and Education Assistance Act (Public Law 93-638), as amended;
  3. contracts or subcontracts whose value is equal to or less than the simplified acquisition threshold, as that term is defined in section 2.101 of the Federal Acquisition Regulation (typically $250,000);
  4. employees who perform work outside the United States or its outlying areas, as those terms are defined in section 2.101 of the Federal Acquisition Regulation; or
  5. subcontracts solely for the provision of products.

Although the Executive Order does not apply in the situations detailed above, agencies or other partners may enact requirements that could apply to participants in Service and Conservation Corps.

Corps may implement vaccination requirements and COVID-19 safety protocols as desired. Corps that already mandate vaccination or regular testing for employees and Corpsmembers should consult with legal counsel regarding the disclosure of vaccination and testing status to external parties (contracting officers, program directors, etc.). Corps whose safety protocols do not yet include mandated vaccination or regular testing should be aware that federal contracts or projects occurring on federal properties may be modified to reflect the objectives of this Executive Order and should consult legal counsel on the development and/or applicability of contract modifications.

In either case, Corps should be advised that federal partners may require that every individual working on or visiting federal properties complete a Certification of Vaccination Form to disclose vaccination status. Workers and visitors who decline to disclose may not be authorized to participate in designated activities and/or on designated areas. The Corps Network encourages Corps leaders to consult with legal counsel in the development of policies and procedures related to the implementation of this Executive Order.

AmeriCorps has not mandated vaccination of members. However, participation in AmeriCorps does not exempt members from adhering to additional requirements or regulations from project partners or sponsors.

We will continue to monitor the guidance from the Safer Federal Workforce Task Force and provide updates or recommendations as this develops.

Additional Resources: