OPM Orders Removal of COVID-19 Vaccine Records from Federal Files
federal employment mindfulness at work mspb appeals opm guidance personnel file expungement Aug 11, 2025On August 8, 2025, the Office of Personnel Management (OPM) issued a government-wide directive requiring agencies to delete all records of federal employees’ COVID-19 vaccination status, any related noncompliance notices, and exemption requests. Agencies are prohibited from using that information in any future employment decision—whether hiring, promotion, discipline, or termination.
This is the final chapter in a policy timeline that began with Executive Order 14043 (Sept. 2021), which mandated vaccination, and ended with Executive Order 14099 (May 2023), which revoked the requirement. The courts closed the primary legal challenge in December 2023, and now OPM has instructed agencies to “clean the slate.”
What “Expungement” Really Means
The directive covers both the paper Official Personnel Folder (OPF) and the electronic OPF. Any disciplinary entries, denied accommodation notes, or other documentation tied to your vaccine status should be removed—unless you actively choose to keep them.
Agencies must complete this process and certify compliance to OPM by September 8, 2025. You have 90 days from the memo date to opt out of deletion. If you do nothing, your records should be removed automatically. If you opt out, you can still request deletion later.
Deciding Whether to Opt Out
For most employees, a “clean file” is preferable. However, if you are involved in active litigation—especially where vaccine records help establish the facts—you may want to preserve them temporarily. Also note: if there is a litigation hold in place, your agency must follow that before deleting records.
Three Practical Steps to Take Now
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Make Your Choice Early
Consider your current legal posture. If you’re in the middle of an MSPB appeal, EEOC case, or other dispute involving vaccine records, speak to your attorney before allowing deletion. -
Verify Deletion
After the 90-day period, log in to your eOPF and confirm the entries are gone. If they remain, send a written request to HR referencing the OPM memo (Aug. 8, 2025). -
Save Your Own Copies
Keep personal copies of any notices, PIP references, or denied accommodations tied to vaccine status. These may still be relevant for MSPB or EEOC actions under federal-sector rules.
A Mindful Perspective
Your personnel file does not define you. This OPM action is an opportunity to release old, contentious entries and move forward. Before you dive into paperwork, pause for one slow breath—inhale through your nose, exhale through your mouth. In a career full of changes, this one offers a chance to reset.
Legal Disclaimer: The information provided in this article is for informational purposes only and should not be construed as legal advice. While I am a federal employment attorney, this post does not create an attorney-client relationship. Every situation is unique, and legal outcomes depend on specific facts and circumstances.
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