Pass Through Vaccine, Mask and Testing Requirements

Effective through Spring Semester 2022

Iowa State University collaborates with many external organizations to provide experiential educational opportunities for our students.  These organizations may have their own mask, testing, and/or vaccine requirements for access to their facilities (referred to as “pass through” requirements).  These requirements are similar to non-COVID-19 external requirements that have been required of our students and employees, such as wearing safety glasses, hairnets, steel-toed shoes, hard hats, getting tuberculosis shots or other vaccines, and signing non-disclosure agreements.    

One distinction with COVID-19-related external requirements is the Board of Regents mandate restricting mask requirements and the State of Iowa mandate restricting vaccine requirements. Similar restrictions with respect to safety glasses, hairnets, steel-toed shoes, etc. are not present.

Examples of “pass through” requirements that we are aware of, or anticipate occurring:

  • A student in a capstone class who is required to complete site visits at a company that has a vaccine requirement in their facility.
  • Student teachers placed in school districts with vaccine requirements.
  • Internships required for graduation in which students are placed in organizations (e.g. nursing homes, hospitals) that have vaccination requirements.
  • Federal requirements – USDA requires masks in all USDA-inspected facilities, including Iowa State’s Meat Lab, where classes are held. 
  • Vaccine requirements imposed by a third-party study-abroad program provider which are passed onto participating ISU study abroad students. 

Mask requirements from a third party:

  • Pass through mask requirements do not violate the Board of Regents directive, as long it is clearly stated that it is not an ISU requirement, but an external requirement. 
  • For official course work or required experiential learning requirements, especially where the university is involved in identifying or matching students with external organizations, departments or units may need to consider alternative arrangements for students to complete the course or degree requirement.  
  • If medical, disability, or religious accommodation is involved, consult with University Counsel.

Vaccine requirements from a third party:

  • Must clearly state that vaccination is a third party requirement, and not an Iowa State requirement. 
  • Two primary factors to consider:  1) Optional vs. Required; and 2) Department Selected vs. Student Selected.
    • (1) If it is an optional experience (e.g. participation in a pitch competition, study abroad experience) alternative arrangements are generally not required.
    • If a third party is imposing a vaccine requirement on the participants of a required course or degree requirement (e.g. an internship needed prior to graduation) then the university may need to explore reasonable alternatives for the student to complete the requirement.
    • (2) If the department or unit is involved in placing or matching students and third-parties then the department/unit generally has more responsibility to consider reasonable alternatives.
    • If the student self-identified and self-selected the third-party, then the department/unit generally has less responsibility to consider alternatives.
  • For capstone courses (or similar courses):
    • Consider providing/identifying industry partner options for the students to choose from, including those that do not have a vaccine requirement.
    • Students can form groups such that the division of work includes some students who could visit the company, while those who can’t would equitably participate in other activities (e.g. some students collect data while others do computer modeling).
    • Students and instructors need to be cognizant that third parties may impose a vaccine or other requirement in the middle of a semester.  Students should be advised of this potential up front, and may consider an alternative assignment if they are not willing to handle this situational ambiguity. 
    • If medical, disability, or religious accommodation is involved, consult with University Counsel.