Storing COVID-19 Vaccination Records and Testing for Work-based Activities

Workforce Services Information Notice
WSIN21-19

Issued: October 25, 2021

Proof and Storage of COVID-19 Vaccination or Weekly Testing for WIOA Participants

Employers may require proof of COVID-19 vaccination or weekly testing as an additional safety standard to protect the health and safety of their worksite. This could directly impact Workforce Innovation and Opportunity Act (WIOA) participants engaged in work-based learning activities (e.g., on-the-job training, work experience, etc.) Local Workforce Development Areas (Local Area) must handle all collection of this medical information as confidential and must comply with WIOA Section 188, if collection is requested by the employer.   

Workforce Services Directive Nondiscrimination and Equal Opportunity Procedures (WSD17-01), provides guidance and establishes procedures regarding nondiscrimination and equal opportunity procedures outlined in WIOA Section 188 and 29 CFR Part 38:

Any medical or disability-related information obtained about a particular individual, including information that could lead to the disclosure of a disability, must be collected on separate forms. All such information, whether in hard copy, electronic, or both, must be maintained in one or more separate files, apart from any other information about the individual, and treated as confidential. Whether these files are electronic or hard copy, they must be locked or otherwise secured (e.g., through password protection).

COVID-19 Vaccination and Testing Resources

COVID-19 vaccines are available at no charge for individuals ages 12 and up, regardless of immigration or insurance status. If necessary, Local Areas can refer WIOA participants to the following resources for vaccination or testing information:

  • My Turn – Provides information about where an individual can book an appointment or find a walk-in site for their COVID-19 vaccine.
  • Find a Testing Site – Allows individuals to search for their nearest COVID-19 test site.

For questions regarding this notice, contact your Regional Advisor for assistance.

/s/ KIMBERLEE MEYER, Chief
Central Office Workforce Services Division