OPM Directs Federal Agencies to Remove COVID Vaccine Records from Personnel Files

The U.S. Office of Personnel Management (OPM) recently issued new guidance requiring all federal agencies to eliminate records of federal employees’ COVID-19 vaccination status.

Effective immediately, federal agencies are barred from using an individual’s vaccine history in any employment-related decisions, including hiring, promotion, discipline or termination, according to an OPM statement regarding the guidance.

The Aug. 8 memo also mandates that federal employers eliminate any records of employees’ prior noncompliance with COVID vaccine mandates, or requests for exemptions from such mandates. Unless an employee affirmatively opts out within 90 days, all vaccine-related information must be permanently removed from both physical and electronic personnel files, according to OPM. Agencies must certify compliance with the memo by Sept. 8, 2025.

As Government Executive’s Erich Wagner recently reported, then-President Joe Biden issued a 2021 executive order obliging all federal employees and contractors to be vaccinated against COVID-19, “as the virus’ Delta variant was gaining steam.”

That edict included medical and religious exemptions, but was challenged in federal court. The order was blocked in 2022 and ultimately revoked in 2023. OPM issued guidance soon after, but the Aug. 8 memo “reiterates and expands on that previous guidance,” wrote OPM Director Scott Kupor.

“Federal agencies may not use an individual’s COVID-19 vaccine status, history of noncompliance with prior COVID-19 vaccine mandates or requests for exemptions from such mandates in any employment-related decisions,” Kupor wrote, “including but not limited to hiring, promotion, discipline or termination.”