December 23, 2021 Update on City Worker Vaccine Requirement 

On December 23, 2021 the City received orders from the Ramsey County District Court to temporarily suspend implementation of the City’s Vaccine Requirement Policy for city workers that are members of three City unions pending further order from the Court. This order comes amid ongoing lawsuits with those unions regarding the City’s implementation of its COVID-19 Vaccine Requirement Policy.  

In response to these orders, pending the outcome of this litigation, we are taking these steps pending further orders from the court: 

  • The City of Saint Paul will postpone enforcement of the Vaccine Requirement Policy citywide. 

  • Our Department of Human Resources will continue to accept proof of vaccination and attestation from city workers who wish to voluntarily provide this information. 

  • Our Department of Human Resources will postpone accepting new requests for medical accommodation or religious exemption and will postpone processing all existing requests for accommodation or exemption.

  • The Vaccine Requirement Policy continues to apply to those newly hired or newly volunteering on or after December 23, 2021.

Download the COVID-19 Vaccination Policy

Statement of Policy 

It is the policy of the City of Saint Paul that all City Workers be vaccinated against COVID-19.  

Policy Overview 

The COVID-19 pandemic presents an unprecedented challenge to our City. The virus is highly contagious, including among asymptomatic people, and potentially deadly. As of October 14, 2021, over 970 of our family members, friends, and neighbors in Ramsey County, and over 8,300 people in the state, have perished from COVID-19. According to the Centers for Disease Control and Prevention (“CDC”) and the Minnesota Department of Health (“MDH”), the best way to prevent infection and spreading the disease is by being vaccinated. COVID-19 vaccines have proven themselves to be safe and effective. 

City Workers (defined as employees, volunteers, and interns) without vaccination pose a risk of COVID-19 exposure to themselves, their colleagues, and to members of the public. Additionally, ongoing community transmission of the more contagious Delta variant of COVID-19 in Minnesota, especially among unvaccinated individuals, presents a continuous risk of infection. 

We all have a shared commitment to protect, the health and safety of our co-workers and the community we serve to the extent reasonably possible, from the direct threat resulting from the spread of COVID-19.  Accordingly, all City Workers must be vaccinated against COVID-19 and provide proof of their COVID-19 vaccination status. If a City Worker does not provide proof of their vaccination and completed COVID-19 Attestation Form, at the time required by the City, they will not be permitted to work and may be subject to discipline.

Experts are still learning more about how long vaccines protect against COVID-19. This policy will be reviewed regularly in conjunction with information from public health experts including the CDC and MDH. This policy is subject to change at the City’s discretion. City Workers may be subject to additional attestation, or vaccinations under state or federal law. 

Requests for Medical Accommodations and Religious Exemptions  

In accordance with the City’s Accommodation policy, the City provides reasonable accommodations, absent undue hardship, to qualified individuals with disabilities to enable them to perform their job duties. Employees who believe they need an accommodation regarding this policy because of a medical condition, or recent treatment for COVID-19 are responsible for requesting a reasonable accommodation from their HR Liaison.  

The City may provide a religious exemption to employees with sincerely held religious beliefs, observances, or practices that conflict with vaccinations. Employees who want to request an exception to this policy because of their sincerely held religious belief are responsible for requesting a religious exemption from the Human Resources Department. Documentation and evidence of a sincerely held religious belief will be required as part of this process. 


This policy applies to all City Workers, defined as employees, volunteers, commission members and interns of the City. 

General Standards and Expectations 

  1. Proof of Vaccination Status 

City Workers in an active employment status must show proof of vaccination and submit to the City a completed COVID-19 Vaccine Attestation Form documenting their COVID-19 vaccination status.  

Acceptable proof that an individual is fully vaccinated against COVID-19 includes: 

  • An original CDC COVID-19 vaccination card 

  • A paper or electronic copy of a CDC COVID-19 vaccination card 

  • If vaccinated in another country, then an original or copy of an alternative official vaccination record, as proof of FDA- or WHO-approved COVID-19 vaccination status 

  • Another official record of vaccination 

  • Confirmation from the State of Minnesota Immunization Information Connection that the employee is fully vaccinated. 

Proof of full vaccination against COVID-19 must legibly show, at a minimum: 

  • Name of the individual vaccinated 

  • Date of birth of the individual vaccinated 

  • The manufacturer of the vaccine 

  • The date(s) on which the vaccine was administered 

If the proof is not legible or verifiable in the form presented the City may ask for the original document. If the City Worker lost their vaccination card they can: 

  • Authorize the state to release information to the City to verify the employee is fully vaccinated, or 

  • Request a copy of their vaccination record from the medical provider where they received the vaccination or 

  • Request a copy of their vaccination card from the State of Minnesota

A vaccinated individual will be considered unvaccinated for the purposes of this policy in these circumstances: 

  • If no attestation and acceptable proof of COVID-19 vaccination is produced as of the effective date of this policy or first date of employment.  

  • If a City Worker is vaccinated but refuses to provide a completed attestation form and proof of vaccination. 

The attestation forms will be treated as private personnel records under applicable law. Information regarding whether a City Worker has shown proof of full vaccination may be provided to the Department Director, HR Liaison, Supervisor, other limited staff with a business need to know, and others as authorized by law. 

  1. Confidentiality of Medical Information 

The City and Departments must maintain the confidentiality of the COVID-19 vaccination status as provided by law. All information gathered under this Policy, including vaccination status, and attestation forms, must be retained by HR according to the applicable retention schedule and in a secure medical file separate from the City Worker’s personnel file. 

COVID-19 vaccination status may be shared with City employees with a business need to know, and others authorized by law. 

Definitions and Key Terms 








  • For purposes of compliance with this policy City Workers must have had their second dose in a 2-dose COVID-19 vaccination series approved by the U.S. Food and Drug Administration (“FDA”) or the World Health Organization (“WHO”); or 

  • A single-dose COVID-19 vaccine approved by the FDA or the WHO by the deadline for vaccination. 

  • Need for booster vaccines are still under review as of this date* 


City Workers who do not meet these requirements are NOT considered vaccinated. 



City Workers 


All regular and temporary employees of the City of Saint Paul, regardless of scheduled hours. This also includes commission members, volunteers and interns.


Departments are responsible for: 

  • Communicating this policy to all City Workers. 

  • Requiring City Workers to comply with this policy. 

  • Monitoring staff compliance with the requirements of this Policy. 

  • Maintaining completed attestation forms in a secure medical file separate from the personnel file. 

  • Working with City HR to ensure vaccination requirements are included in the interviewing and hiring process; documented in offer letters and job announcements; and completed in the pre-employment phase of onboarding. 

  • Department HR Liaisons are required to accept and process medical accommodation requests and communicate with the City Accommodation Coordinator. 

  • Directing requests for religious exemptions to the Human Resources Director or their designee. 

Employees are responsible for: 

  • Complying with this policy. 

Human Resources is responsible for: 

  • Publishing the policy. 

  • Assisting departments in the implementation and administration of the policy. 

  • Reviewing and updating the policy as needed. 

  • Issuing and updating relevant communications, templates, and guidance.  

  • Ensuring compliance with the data retention and privacy aspects of the policy. 

Last Edited: April 4, 2022