Declaration Of Ryan Rapp,

Summary

The Declaration of Ryan Rapp, Executive Vice President for Finance and Operations of the University of Missouri System, filed 11/04/21 as Doc. 9-6 in Case 4:21-cv-01300-DDN, states that the University holds federal contracts anticipated to fall within the federal contractor COVID-19 vaccination mandate under Executive Order 14042, conservatively estimated to exceed 230 in number, with annual revenues exceeding $20 million in the 2020/21 fiscal year and a multi-year value exceeding $76 million. It states that in excess of 9,000 employees have salaries supported by those contracts, that the University has in excess of 22,000 employees not counting student employees, and that the vaccination requirements can be anticipated to lead to resignations, terminations, recruitment limits and significant additional costs.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

Case: 4:21-cv-01300-DDN Doc. #: 9-6 Filed: 11/04/21 Page: 1 of 5 PageID #: 258
EXHIBIT
Case: 4:21-cv-01300-DDN Doc. #: 9-6 Filed: 11/04/21 Page: 2 of 5 PageID #: 259
DECLARATION OF RYAN RAPP,
UNIVERSITY OF MISSOURI SYSTEM

I, Ryan Rapp, being first duly sworn upon my oath, do hereby state as
follows:

1. I am the Executive Vice President for Finance and Operations of the
University of Missouri System. I am also a resident of Missouri and over the age
of majority. I have personal knowledge of the facts in this declaration, and those
facts are true and correct to the best of my knowledge.

2. The University of Missouri System (“the University”) includes four
universities, a health system and an extension division, along with numerous
research parks, business incubators, health centers and affiliates.

3. In the performance of its statutory duties, the University
participates with the federal government on a variety of programs, including as a
contractor to the federal government, and receives federal funds for the
completion of certain responsibilities.

4. The University of Missouri is a contractor with numerous federal
agencies in numerous contracts anticipated to fall within the scope of the federal
contractor COVID-19 vaccination mandate under Executive Order 14042. Such
contracts are conservatively estimated to exceed 230 in number, with annual
revenues to the University exceeding $20 million in the 2020/21 fiscal year, and
an estimated total, multi-year value exceeding $76 million. Depending on how

federal agencies interpret and apply the scope of Executive Order 14042 and
Case: 4:21-cv-01300-DDN Doc. #: 9-6 Filed: 11/04/21 Page: 3 of 5 PageID #: 260
associated federal guidance, and on the extent to which agencies deploy contract
clauses requiring compliance with COVID-19 vaccination requirements, the
number and value of contracts affected by such requirements could be
substantially greater. The amount of many of the contracts exceed the simplified
acquisition threshold defined in Section 2.101 of the Federal Acquisition
Regulation.

5. It is conservatively estimated that in excess of 9,000 employees have
salaries supported directly by funding from the contracts noted in paragraph 4 or
included within the University’s facilities and administration costs (“F&A”) on
such contracts. Depending on how federal agencies interpret and apply the scope
of Executive Order 14042 and associated federal guidance, and on the extent to
which agencies deploy contract clauses requiring compliance with COVID-19
vaccination requirements, the number of such employees could be substantially
greater.

6. Considering the scope of COVID-19 employee vaccination
requirements identified in “COVID-19 Workplace Safety: Guidance for Federal
Contractors and Subcontractors” issued by the Safer Federal Workforce Task
Force in connection with Executive Order 14042, compliance with federal
contracts incorporating clauses establishing such vaccination requirements
ultimately place the University in the position of having to require COVID-19
vaccination for all or virtually all of its employees. Not counting student

employees, who also would be affected by the vaccination requirements, the
Case: 4:21-cv-01300-DDN Doc. #: 9-6 Filed: 11/04/21 Page: 4 of 5 PageID #: 261
University has in excess of 22,000 employees.

7, Based on the general percentage of Missourians who have chosen not
to take a COVID-19 vaccine, it can reasonably be anticipated that COVID-19
vaccination requirements established in connection with federal contracts would
lead a significant number of employees to resign or be terminated.

8. Some number of employees terminated by the University for refusal
to comply with COVID-19 vaccination requirements established in connection
with federal contracts would likely apply for unemployment benefits. Assuming
such benefits were granted, this would impose a significant additional financial
cost to the University.

9. Implementing compliance with federal contract clauses establishing
COVID-19 vaccination requirements can reasonably be anticipated to result in
significant additional costs to the University in performance of those contracts
and more broadly in conducting its operations. Such significant additional costs
would include, but not be limited to, resources spent on managing verification of
vaccination status, review of accommodation requests, implementing
accommodations, and potentially in ensuring separation of covered and non-
. covered employees.

10. The recruitment of qualified employees is a significant consideration
by the University. It reasonably can be anticipated that COVID-19 vaccination
requirements established in connection with federal contracts would limit the

number of potential applicants.
Case: 4:21-cv-01300-DDN Doc. #: 9-6 Filed: 11/04/21 Page: 5 of 5 PageID #: 262
11. It reasonably can be anticipated that such issues of resignations,
terminations, and recruitment will interfere with the University’s ability to
administer services pursuant to its constitutional and statutory mission.

Pursuant to 28 U.S.C. 1746, I declare under penalty of perjury that the

foregoing is true and correct.

Executed on this 4 day of November, 2021.

Gon Bayz
Ryai Rapp — /f{/

Executive Vice President for Finance and Operations
University of Missouri System


File and source

File

Missouri_EDMO_4-21-cv-01300_8th-21-3725__doc-009__att-06.pdf

Size

228,466 bytes

SHA-256

029a1e3ee1b8b5dc4a2aabf7c2642e5d0d3b365825edd754468297fb2225dec9

Our copy

Missouri_EDMO_4-21-cv-01300_8th-21-3725__doc-009__att-06.pdf

Original

storage.courtlistener.com