Employees of most federal contractors have until Dec. 8 to be fully vaccinated against COVID-19 under President Joe Biden’s recent executive order mandating such vaccinations, according to guidance issued by the Safer Federal Workforce Task Force Sept. 24.

The mandate applies to contracts with all executive branch agencies under Federal Acquisition Regulation and above the simplified acquisition threshold — meaning a contract above $250,000, except in limited circumstances where the contract relates to disaster recovery, humanitarian work or attack recovery and defense.

Contracts already in existence will have a clause requiring compliance with the task force guidance applied at the next option exercised or extension made, meaning their employees would fall under the mandate at that point.

“After that date, all covered contractor employees must be fully vaccinated by the first day of the period of performance on a newly awarded covered contract, and by the first day of the period of performance on an exercised option or extended or renewed contract when the clause has been incorporated into the covered contract,” the guidance states.

Any solicitation issued after Oct. 15 or contract awarded after Nov. 14 will have to have the COVID-19 clause included as part of the award.

The mandate not only applies to contractor employees working at government worksites, but any employee working on or in connection with a covered government contract. Contractor employees that are not working on a covered government contract, but are still working at the same worksite as employees on the contract must also receive a vaccine.

The guidance also requires contractors to designate a person to coordinate implementation of the vaccine mandate and workplace safety requirements.

In other regards, the vaccine requirements for federal contractors are much the same as for federal employees, including the potential for religious or medical exemption and the official documentation requirements for proof of vaccination.

Agency heads may also authorize a 60-day exception for contract employees that must begin work of “an urgent, mission-critical need” and are not yet fully vaccinated, though such employees are expected to be immunized against COVID-19 by the end of that period.

Contractors must also match the federal government’s masking and social distancing procedures, which require unvaccinated persons to be masked at all times indoors and in crowded outdoor scenarios and require vaccinated employees to wear masks in communal areas in locations of high community transmission.

Federal contractors that are responsible for subcontractors will also be required to include a compliance clause in their agreements with those subcontractors.

Jessie Bur covers the federal workforce and the changes most likely to impact government employees.

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