September 29, 2021

The Department of Defense (“DoD”) recently published Force Health Protection Guidance Memorandum (Supplement 23), which provides direction for individuals (including contractor employees) who must access DoD facilities to perform their jobs.  The memorandum imposes vaccination and testing requirements to reduce the spread of COVID-19 at DoD facilities. Individuals who visit DoD facilities are now required to attest to their vaccination status by completing a DD Form 3150 or provide a negative COVID-19 test administered at least 3 days prior to their visit.  

These requirements apply to all individuals issued a DoD credential allowing that person recurring access to DoD facilities.  They also apply to individuals seeking access to DoD facilities on a one-time or non-recurring basis in association with the performance of official DoD business.  The memorandum does not apply to individuals who only have occasional informal access to DoD facilities such as delivery personnel or taxi services, those who only access the facility grounds but not the buildings, or those who access DoD public benefit facilities such as a commissary or museum.

If accessing another agency’s facility on a DoD installation, individuals must comply with the applicable policies of both the agency they are visiting and the DoD.  Civilian and contractor personnel who are unvaccinated for COVID-19 or who decline to attest to their vaccination status will be subject to COVID-19 testing at least weekly.  Individuals who refuse required testing will be denied access to DoD facilities.

Government contractors and subcontractors who have employees subject to the requirements in the memorandum should ensure that those employees understand and comply with these requirements.