Vaccine requirements for federal contractors: The latest Task Force guidance basics

By Jeff Ellinport, Division Counsel

As anticipated in my last blog, on September 24, 2021, the White House’s Safer Federal Workforce Task Force issued its expected guidance implementing the vaccination requirements for federal prime contractors and subcontractors. This action was pursuant to Executive Order 14042 (Ensuring Adequate COVID Safety Protocols for Federal Contractors) that President Biden issued on September 9.

While the guidance directly answered some questions posed in my last blog, it also created others. Here are the basics.

Requirements

The guidance sets out three main requirements:

  1. COVID-19 vaccination of covered contractor employees, except in limited circumstances where an employee is legally entitled to an accommodation
  2. Compliance by individuals, including covered contractor employees and visitors, with the guidance related to masking and physical distancing while in covered contractor workplaces
  3. Designation by covered contractors of a person or persons to coordinate COVID-19 workplace safety efforts at covered contractor workplaces
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Vaccine requirements for federal contractors: What we know today

By Jeff Ellinport, Division Counsel

In the next 10 days, expect specific guidance on how federal contractors will need to respond to the COVID vaccine mandate from the Biden administration.

On September 9, 2021, President Biden issued an Executive Order “Ensuring Adequate COVID Safety Protocols for Federal Contractors” (the “EO”). This order will require many federal contractors to have their employees either fully vaccinated or subject to regular COVID-19 testing.

Here is what we know 

The EO leaves some of the details regarding the requirements for federal contractors to others. Specifically, the Department of Labor’s Occupational Safety and Health Administration (OSHA) is to issue an Emergency Temporary Standard (ETS) in a few weeks, and the recently created Safer Federal Workforce Task Force (the “Task Force”) is to issue specific federal contractor guidance by September 24.

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