COVID-19 vaccination requirement for supplier personnel

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As of November 15, 2021, all supplier personnel must meet a vaccination requirement to access federal government workplaces inside and outside Canada where they may encounter federal public servants. Suppliers are required to provide a certification form to their contracting authority.

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Vaccination requirement for supplier personnel

The vaccination requirement of the COVID-19 Vaccination Policy for supplier personnel applies to all new and existing Government of Canada contracts that involve services (including goods contracts that have a services component and construction services) where, in order to perform the work, supplier personnel require access to Government of Canada workplaces (i.e., places of work owned or operated by the Government of Canada) where they may come into contact with public servants. It also applies to certain site visits and bidders’ conferences.

The vaccination requirement does not apply to:

  • contracts that are solely for the provision of goods;
  • contracts where the only services component is delivery;
  • contracts where services are solely performed in non-federal government workplaces;
  • situations where federal employees must enter supplier facilities (for example: to conduct compliance audits or security verifications);
  • contracted personnel who will only access common areas of buildings that are open to the public (such as the lobby).

Meeting the vaccination requirement

To meet the vaccination requirement, supplier personnel must be:

  1. fully vaccinated;
  2. unable to be vaccinated due to a certified medical contraindication, religion or other prohibited grounds of discrimination under the Canadian Human Rights Act and subject to approved accommodation and mitigation measures; or (b) unable to be vaccinated due to a certified medical contraindication, religion or other prohibited grounds of discrimination under the Canadian Human Rights Act and subject to approved accommodation and mitigation measures; or
  3. for a period of up to 10 weeks from the date of their first dose, partially vaccinated and subject to approved temporary measures.

Fully vaccinated

If providing services in Canada, supplier personnel are considered fully vaccinated 14 days after they have either:

  • Received both doses of a Health Canada authorized vaccine that requires 2 doses to complete the vaccination series;
  • Received a mixed-dose vaccination series, as long as it aligns with National Advisory Committee on Immunization (NACI) Recommendations on the use of COVID-19 vaccines;
  • Received 1 dose of a Health Canada authorized vaccine that only requires 1 dose to complete the vaccination series (as of September 16, 2021): Janssen (Johnson & Johnson) COVID-19 vaccine;
  • For current residents of Quebec only, have had a laboratory-confirmed COVID-19 infection followed by at least 1 dose of a Health Canada authorized COVID-19 vaccine.

If providing services outside Canada, supplier personnel are considered fully vaccinated as defined in the Fully Vaccinated - COVID-19 (employees vaccinated outside of Canada as of October 6, 2021) section of the Treasury Board of Canada Secretariat’s Policy on COVID-19 Vaccination for the Core Public Administration Including the Royal Canadian Mounted Police.

For more information on accepted COVID-19 vaccines, you can consult the Vaccines for COVID-19 page.

Duty to accommodate

Some supplier personnel may not be able to be fully vaccinated due to a certified medical contraindication religion or other prohibited grounds of discrimination under the Canadian Human Rights Act.

In such cases, suppliers are expected to inform the responsible contracting authority as soon as possible of:

  • the number of such personnel unable to be vaccinated;
  • the impacted work locations;
  • the steps the supplier proposes to undertake to mitigate any associated risks (such as regular mandatory testing).

Accommodation and mitigation measures are subject to approval by the technical authority and must adequately ensure the health and safety of public servants.

Unless specifically requested, suppliers should not share any personal information with the contracting authority, including specifics about:

  • medical contraindications;
  • the applicable prohibited grounds of discrimination under the Canadian Human Rights Act.

Partially vaccinated

Supplier personnel who are partially vaccinated may continue to access Government of Canada workplaces to perform contracted work, subject to approved temporary measures until they can become fully vaccinated.

These temporary measures are only to be used for a maximum 10-week period that begins on the date the supplier personnel received their first dose. By the end of the 10-week period, the temporary measures for the partially vaccinated personnel in question may no longer be used and the supplier personnel should be:

  • fully vaccinated; or
  • if it became known during the 10-week period that the supplier personnel is unable to become fully vaccinated due to a certified medical contraindication, religion or other prohibited grounds of discrimination under the Canadian Human Rights Act, the supplier personnel should be subject to mitigation measures that have been presented to and approved by Canada.

If the 10-week period concludes with the supplier personnel not fully vaccinated or subject to mitigation measures as outlined above, the temporary measures will no longer be permitted and the partially vaccinated supplier personnel in question will no longer be permitted to access Government of Canada workplaces where they may come into contact with public servants until such time that they become fully vaccinated.

Certification Process

Existing contracts awarded prior to November 15, 2021

Suppliers whose personnel access Government of Canada workplaces where they may come into contact with public servants to perform work must certify that their personnel who access these workplaces will meet the vaccination requirement. To submit their certification form(s), suppliers should follow the process outlined to them in the letter or email they received from the specific department(s) with which they have contracts. Suppliers who do not submit the certification form(s) may be subject to further measures, up to and including termination.

Existing contracts awarded prior to November 15, 2021 – Instructions for Public Services and Procurement Canada (PSPC) suppliers only

Suppliers who have contracts with Public Services and Procurement Canada are all to submit an attestation. To submit their attestation, and, if applicable, certification form, suppliers with existing contracts with PSPC should follow the process outlined to them in the letter or email they received from PSPC. Even if their contracts do not require access to Government of Canada workplaces, suppliers who have existing contracts with PSPC are still required to complete the online Federal Supplier Vaccination Attestation (though, in this case, they do not need to complete or submit the certification form).

If you are a PSPC supplier with existing contracts and did not receive the email(s) from PSPC, complete the steps below to submit your attestation and, if applicable, certification form to PSPC.

  1. Locate your contract number(s) and Procurement Business Number;
  2. Download, complete and sign the COVID-19 Vaccination Requirement Certification Form (PDF, 67KB);*
  3. Complete the online Federal Supplier Vaccination Attestation and attach the COVID-19 Vaccination Requirement Certification Form (if applicable).

*A fully accessible web format of the form is not currently available. For any questions or needs relating to accessibility, please send an email to: tpsgc.pacertificatsvaccins-apvaccinescertificates.pwgsc@tpsgc-pwgsc.gc.ca.

Future contracts

Contracting authorities are including new clauses in the solicitation documents of new in-scope solicitations to implement the vaccination requirement. For active in-scope solicitations, the documents will be amended before the closing date to include the relevant clauses. This may result in an extension of the bid period to provide bidders with additional time to complete their bids.

As a result of these clauses, bidders for contracts that may require supplier personnel to access federal government workplaces where they may come into contact with public servants must certify they meet the vaccine requirement by submitting a certification form as part of the bid. Bids that do not include the certification form will be found non-responsive.

Monitoring

Certifications provided to Canada are subject to verification at all times. This includes Canada reserving the right to request proof of vaccination from supplier personnel when accessing a federal government workplace and to request supporting documentation from suppliers.

Additionally, Government of Canada departments are responsible for implementing a framework to ensure that suppliers comply with their certification. This framework will vary depending on the department and workplace(s) in question, and may include on-site verification of an individual supplier personnel’s vaccination status. Suppliers should contact the contracting authority to determine if there are verification requirements for specific locations.

Non-Compliance

For new and active solicitations, completing and providing the COVID-19 Vaccination Requirement Certification Form is a mandatory requirement of the bid. If the bidder is unwilling to provide the certification form, then the bid will be found non-responsive.

For existing contracts, if the supplier is unwilling or fails to provide a duly completed certification form, where a certification has been determined to be untrue, or, where a supplier fails to comply with the certification or the COVID-19 Vaccination Policy for supplier personnel, then means to ensure compliance, up to and including contract terminations, will be pursued.

Privacy

Any information that suppliers provide on their certification form or in response to the requirements of the Government of Canada’s COVID-19 Vaccination Policy for supplier personnel, will be protected, used, stored and disclosed in accordance with the Privacy Act.

The Government of Canada does not require suppliers to disclose the details of the vaccination status of their personnel in order to submit a certification. Unless specifically requested, suppliers should not provide any personal information, such as specifics about vaccination status, medical contraindications, or other prohibited grounds of discrimination under the Canadian Human Rights Act with Government of Canada contracting authorities. Suppliers should, however, keep sufficient information on record, to substantiate their compliance with their certification in case verification is required.

Duration

The vaccination requirements of the COVID-19 Vaccination Policy for supplier personnel will be time-limited to the COVID-19 pandemic. The Policy will be reassessed at a minimum every six months, or as prescribed by the Treasury Board of Canada Secretariat.

Frequently Asked Questions

Q.1. Why is the Government of Canada establishing a vaccination requirement for supplier personnel?

The COVID-19 pandemic continues to have an unprecedented impact on the health of Canadians. COVID-19 vaccines are a critical tool that reduce the risk of COVID-19 and protect broader public health. As a responsible employer, the Government of Canada is committed to protecting the health and safety of its employees.

On October 6, 2021, the Government of Canada announced its Policy on COVID-19 Vaccination for the Core Public Administration Including the Royal Canadian Mounted Police. In alignment with this approach, the Government of Canada also established the COVID-19 Vaccination Policy for Supplier Personnel, which requires that all supplier personnel who access Government of Canada workplaces where they may come into contact with public servants also meet a vaccination requirement.

Vaccination is one of the most effective ways to protect our employees, workplaces, and communities against COVID-19. Currently available COVID-19 vaccines are very effective at preventing severe illness, hospitalization, and death from COVID-19, including against the more infectious variants of concern. Fully vaccinated individuals are less likely to be infected or transmit infection to others.

Q.2. Who are considered “supplier personnel”?

For the purpose of the COVID-19 Vaccination Policy for Supplier Personnel, the term “supplier” includes bidders, contractors, offerors, and suppliers (in the context of Supply Arrangements).

“Personnel” means all persons employed by the supplier or conducting work for or on behalf of the supplier under a contract with the Government of Canada. This includes, but is not limited to, subcontractors, subcontractors’ employees, consultants and agents.

Q.3. Does the COVID-19 Vaccination Policy for Supplier Personnel apply to outdoor workplaces (for example, docks, dams, parks) or construction sites/facilities?

Vaccination requirements apply to all Government of Canada workplaces where supplier personnel may come into contact with public servants, whether they are indoor or outdoor. This includes Government of Canada owned or operated outdoor workplaces or construction sites/facilities.

Q.4. Does the COVID-19 Vaccination Policy for Supplier Personnel apply to federal construction sites that are under the custody of the construction manager?

The policy applies only to federal workplaces where supplier personnel may come into contact with public servants. If public servants do not work on the site, the policy does not apply. This policy is in addition to all applicable Occupational Health and Safety requirements in a contract.

Q.5. Does the COVID-19 Vaccination Policy for Supplier Personnel apply to publicly-accessible areas of federal buildings or properties such as food courts and lobbies, that are not exclusively workplaces?

The policy applies only to areas where public servants are engaged in work. It does not apply to publicly-accessible areas of federal properties. Supplier personnel who are accessing or performing work exclusively in public areas of federal properties (such as food courts and lobbies) are not subject to vaccination requirements.

Q.6. Does this policy apply to Government of Canada sites where no employees are present?

No. The policy applies only to Government of Canada contracts where, in order to perform their work, supplier personnel access federal workplaces where they may come into contact with public servants. It does not apply to sites where supplier personnel cannot come into contact with public servants. It also does not apply to government-supplied residential space.

Q.7. Does the COVID-19 Vaccination Policy for Supplier Personnel apply to visitors to Government of Canada workplaces?

No. The policy applies only to supplier personnel who are:

  • performing contracted work at a federal government location
  • accessing the workplace for the purpose of a bidders’ conference or site visit

Q.8. Does the COVID-19 Vaccination Policy for Supplier Personnel require that all of a supplier’s personnel meet the vaccination requirement?

No. The policy applies only to personnel who will be accessing Government of Canada workplaces where public servants may be present in order to perform work pursuant to a contract with the Government of Canada. For example, if you have personnel that work exclusively at non-Government of Canada facilities, they are not subject to the policy’s vaccination requirements.

Q.9. Are supplier personnel who are working remotely (teleworking) required to meet the vaccination requirement as well?

It depends on the situation. If the services are delivered 100% remotely (for example, remotely delivered IT services), the vaccination requirement would not apply because supplier personnel would not be accessing Government of Canada workplaces. However, the vaccination requirement would apply to supplier personnel who predominantly work remotely but sometimes have to access Government of Canada workplaces.

The vaccination and certification requirements apply any time a supplier is required to work on-site (or return to working on-site) at a Government of Canada workplace where public servants may be present.

Q.10. Will bidders need to meet the vaccination requirement for site visits or bidders’ conferences?

The vaccination requirement applies if bidders’ conferences or site visits will take place at Government of Canada workplaces where supplier representative(s) may encounter public servants. In such cases, supplier representatives must provide a separate certification indicating that they meet the policy’s vaccination requirements. This must be submitted to the contracting authority in advance of the conference or site visit.

Q.11. How does the policy apply to international contractors?

The policy applies to international contractors in the same way it applies to contractors performing work in Canada. However, a different definition of “fully vaccinated” may apply. For example:

  • International contractors delivering services in Canada are subject to the “in Canada” definition of fully vaccinated
  • International contractors delivering services outside of Canada (for example, at a Canadian mission) are subject to the “outside of Canada” definition of fully vaccinated

Q.12. How many certification forms does a supplier need to submit?

When you submit a certification form, you must include the specific contract number to which the certification applies.

For existing contracts, there are two possible certification forms: one that covers a single contract, and one that covers multiple contracts. For example, if you have 3 in-scope contracts with a department, all 3 contracts can be listed on a single certification form. However, if you have contracts with multiple departments, you will need to submit at least one certification form per department. This process also applies to call-ups under existing standing offers.

For new contracts, certifications will be done for each new solicitation as part of the bid. This includes solicitations under Supply Arrangements. For new Standing Offers, the certification will be done at the Request for Standing Offer stage.

Q.13. Are suppliers required to provide a certification form for each employee?

No. As a supplier, you only need to submit a single certification form attesting that all the personnel you will provide on a specific contract or contracts for which they will access Government of Canada workplaces where they may encounter public servants will meet the vaccination requirement.

Q.14. Do the COVID-19 vaccination requirements apply to all of a supplier’s subcontractors, and if so, who is responsible for ensuring this requirement is met?

The prime contractor is responsible for ensuring all of their subcontractors meet the vaccination requirement. They must certify on behalf of their subcontractors when subcontractor personnel will access Government of Canada workplaces where public servants may be present. It is the prime contractor’s responsibility to ensure subcontractor compliance.

Q.15. Are departments and agencies requiring suppliers to collect and submit vaccination certification forms from subcontractors as well?

The policy only requires a certification from the prime contractor. It is the prime contractor’s responsibility to ensure subcontractor compliance. Prime contractors do not need to send additional certifications to departments for each of their subcontractors.

Q.16. If a supplier is replacing a resource on a contract for which they have already submitted a certification form, is a new certification form required?

No, a new certification form would not be required. As a supplier, the certification requires you to provide personnel that meet the vaccination requirement. Therefore, you would need to replace the resource with one who meets the vaccination requirement.

If the replacement resource is unable to get vaccinated (for example, due to a certified medical contraindication) or is partially vaccinated, you must have mitigation measures or temporary measures approved by the technical authority in advance of the replacement. However, a new certification form would not be required.

Q.17. Are suppliers required to provide a certification form every time they participate in a Government of Canada solicitation?

Yes. A certification requirement will be included in all solicitations that fall under the policy. All personnel you intend on providing under the specific contract must adhere to the vaccination requirement.

Q.18. Do all current contractors (for example, contractors who do not perform work at Government of Canada workplaces where they may encounter public servants) need to submit a certification form?

No. You only need to submit the certification form if you have personnel who access Government of Canada workplaces where they may come into contact with public servants to perform their work.

Q.19. Is the Government of Canada responsible for providing accommodations such as testing to supplier personnel who are unable to be vaccinated?

No. As a supplier, you are responsible for providing the resources and covering the costs of the accommodation and mitigation measures for your personnel (for example, testing costs). However, any proposed accommodation and mitigation measures for personnel who are unable to be vaccinated is subject to approval by the Government of Canada before they can access a Government of Canada workplace where public servants may be present.

Q.20. If I have partially vaccinated personnel that need to be subject to temporary measures, what do I need to do to get the temporary measures approved?

For the purpose of the COVID-19 Vaccination Policy for Supplier Personnel, “partially vaccinated’ refers to supplier personnel who have received 1 dose of a Health Canada authorized vaccine. They have not received a full vaccination series, and therefore do not meet the definition of fully vaccinated.

You are expected to inform your contracting authority as soon as possible of the:

  • number of partially vaccinated personnel
  • impacted work locations
  • temporary measures you propose to undertake to mitigate any associated risks

Please note that temporary measures are subject to approval by the technical authority and must be adequate to ensure the health and safety of public servants.

Q.21. What should I do if I have partially vaccinated personnel that I would like to use on a contract, but the certification form I submitted does not say anything about partially vaccinated supplier personnel?

In order to provide partially vaccinated personnel, you must account for them on your certification form for the contract. Suppliers cannot provide partially vaccinated personnel if it is not explicitly stated in the certification form that they may do so. If you have already submitted a certification form that does not explicitly mention partially vaccinated personnel but you wish to use them, please contact the responsible contracting authority.

Q.22. Are there examples of accommodation and mitigation measures or temporary measures that may be acceptable?

Accommodation and mitigation measures are approved on a case-by-case basis by the technical authority. They must adequately ensure the health and safety of public servants. Examples of acceptable measures include:

  • telework for personnel (where possible)
  • regular mandatory COVID-19 testing for personnel who are unable to telework. Personnel must report test results to their employer. If positive:
    • personnel will not access the Government of Canada workplace
    • personnel will leave the workplace immediately, if they are already there
    • employer will retain a record of the test results
  • other COVID-19 preventative measures (in addition to testing) such as:
    • masks and physical distancing in the workplace as required
    • following public health guidelines

If none of the above measures can be used, you should work with the contracting and technical authorities to determine if there are other measures that would ensure the health and safety of public servants at the workplace.

Q.23. In cases where a supplier’s personnel has been approved for accommodation and mitigation or temporary measures that include regular mandatory testing, are suppliers required to keep proof of negative COVID-19 tests/doctor’s note on file?

Personnel who undergo regular mandatory COVID-19 testing should report their results to their employer. As the employer, you are responsible for retaining a record of the test results. However, you do not need to report these results to the contracting authority unless requested.

Q.24. If I have personnel who are able, but not willing, to be vaccinated, what are my next steps?

Accommodation and mitigation or temporary measures are not available for personnel who are able, but not willing, to be vaccinated. As a supplier, you must not send these personnel to Government of Canada workplaces where public servants may be present until either:

  • they meet the vaccination requirement
  • the COVID-19 Vaccination Policy for Supplier Personnel is no longer in effect

Q.25. Will there be on-site verification of an individual supplier personnel’s vaccination status, such as point-of-entry verification?

Departments are responsible for implementing a framework to ensure suppliers comply with the policy. This framework will vary depending on the department and workplace, and may include on-site verification of an individual supplier personnel’s vaccination status. You should contact the contracting authority to determine if there are on-site verification requirements for specific locations.

Q.26. What happens if contracting or technical authorities have concerns about a supplier’s compliance with their vaccination certification?

If contracting or technical authorities have concerns about a supplier’s compliance with their COVID-19 Vaccination Requirement Certification or have reasons to think that a supplier’s COVID-19 Vaccination Requirement Certification is untrue, they may request additional information from the supplier to verify the certification’s validity.

Please note that vaccination certification compliance is subject to verification by Canada. The contracting authority has the right to ask for additional information to verify your compliance with the certifications.

Canada may declare a contractor in default if it finds a certification untrue, whether knowingly or unknowingly, during the contract period. Further, failure to comply with any request (such as a request for additional information) or requirement imposed by Canada will constitute a default under the contract.

Q.27. What steps are being taken to promote the consistent application of the Government’s COVID-19 Vaccination Policy for Supplier Personnel?

All federal contracting departments and agencies across the Government of Canada have received the same direction regarding the COVID-19 Vaccination Policy for Supplier Personnel, and are expected to implement the same requirements.

Q.28. What should a supplier do if they have been contacted by a department about submitting a vaccination certification for a contract, but the work on that contract has been completed and the contract has ended?

If the work on a contract has been completed and the contract has ended, you do not need to submit a certification. Instead, suppliers should simply respond to the relevant department to inform them that the particular contract has ended.