Federal Vaccine Mandate UPDATE—New Info for Federal Contractors

We have heard from many of you asking for the details on the recently-announced 3-prong federal vaccine mandate.  As a reminder—President Biden announced Executive Orders outlining expectations for a vaccine mandate for federal government contractors and for health care workers, and a mandate/testing requirement for employers with 100+ employees.  The Biden Executive Order announcement from a few weeks ago just set the expectation, and now we are starting to hear what the rules will look like.

First up—federal government contractors. On Friday 9/24 the Safer Federal Workforce Task Force issued some guidance.  Full document can be found HERE.

Highlights:

  • Covered Contractors must ensure all full-time or part-time employees working in connection with a covered contract (including fully remote workers), or working at a covered contractor workplace are fully vaccinated for COVID-19 by December 8, unless the employee is legally entitled to an accommodation.  There is no testing option.
  • Covered contractors must ensure all individuals (except fully remote workers), including employees and visitors, comply with published CDC guidance for masking and physical distancing at the covered contractor workplace. 
  • Covered contractors must designate someone to coordinate the implementation of and compliance with these workplace safety protocols at covered contractor workplaces.  These can be new additional duties for an existing employee.

That’s it for now—but as we learn more about the other elements of the federal vaccine mandate (healthcare workers and companies with 100+ employees) we will share!

Meredith S. Campbell
Chair Employment and Labor Group
Co-Chair Corporate Investigations, Governance & Risk Management

Email [email protected] T(301)255-0550