Agencies had to overcome legacy technology and privacy challenges as they quickly learned to collect, store and protect vaccination data.
To meet the federal government’s September 2021 mandates requiring all executive branch employees and contractors to be fully vaccinated, one agency had digital forms ready within a couple days.
“The customer gave Adobe 24 hours to create several working forms that were ultimately going to be accessed by over 200,000 individuals – employees, contractors, visitors. One was a form to track employee and contractor vaccination status, and there was another form for return to work,” said Heather Whitlock, head of public sector for Adobe Document Cloud. “The agency was able to deploy those production-ready forms in a matter of days, and they received very high response rates, which is critical as you’re trying to manage return to work.”
Initially, employees filled out the digital form to confirm their vaccination status and used an e-signature to validate it. Now, the agency requires additional supporting documents, but by the Biden administration’s November 2021 deadline, it had a compliance rate of almost 99%.
Having that vaccination data "gives them the information that they need to make timely decisions on how to create an environment that’s safe," Whitlock said.
Other agencies can adapt the forms to include the information, language and branding they need.
Although agencies have often promoted healthy lifestyles, the collection and storage of vaccination data on employees is new for many of them. As a result, they are contending with many challenges simultaneously: compliance with privacy requirements, outdated technology and learning how to collect, store and protect vaccination data as it comes in – and quickly.
“The paper-based processes and the outdated online experiences are presenting a lot of challenges that are slowing delivery and creating bottlenecks,” Whitlock said.
One way to alleviate, if not avoid, those bottlenecks is through automation, said Ajay Bhatia, general manager of digital compliance at Veritas Technologies. For instance, agencies can tag personally identifiable information as it comes in using a classification engine that can match data to an agency’s vaccine policy. The engine can flag an entry if it needs additional action, or it can usher the data on to its destination.
Other approaches are separating vaccination data from other personnel data or segregating vaccination data for workers based on location.
“A certain percentage of your workforce will forever be remote. That’s the new normal,” Bhatia said, adding that agencies should “collect the minimum information necessary, which is just the vaccination information for employees who will be onsite.”
What’s more, agencies should set a retention schedule for vaccination data, deleting it as soon as it’s considered expired. According to the Occupational Safety and Health Act, that could be awhile. The Equal Employment Opportunity Commission requires that vaccination data be treated as confidential medical information, and OSHA requires medical records to be retained for the tenure of the employee plus 30 years.
Another challenge is cultural, not technological, in nature. “This is a new type of information. People aren’t used to being able to share it, they don’t feel [it’s] necessary that they need to do it, and it’s all considered a phase that’s quickly passing us by,” Bhatia said.
Legal action against the vaccination requirements could also have an impact. A federal district court in Texas on Jan. 21 blocked the Biden administration’s requirement that federal workers get a COVID-19 vaccine. The directive is on hold pending a Justice Department appeal of the ruling. Earlier this month, three states sought to block a mandate for contractors to be vaccinated.
But the technology is here to stay because it can be adapted for other use cases, Whitlock said. She pointed to the “Executive Order on Transforming Federal Customer Experience and Service Delivery to Rebuild Trust in Government.” Issued in December 2021, it calls for digital tools to bring about better CX.
“If we think about leveraging digital document workflows and electronic signatures, you can really apply that to almost nearly every government operation back office, whether it be [human resources], IT, legal, compliance, procurement, etc., or the mission-facing programs as well,” Whitlock said.
Overall, the experience offers agencies a learning opportunity, Bhatia said.
“Getting a little bit more proactive about the intelligent capture of data and then optimizing your envelope to say here’s the information, here’s how it helps us in regulatory compliance, here’s how it helps us in analytics, I think that level of maturity, it has to come up,” he said.
Stephanie Kanowitz is a freelance writer based in northern Virginia.
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