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Safer Federal Workforce Task Force Guidance for Federal Contractors/Subcontractors

Federal Contractors (also includes subcontractors) will be required to mandate vaccinations of “covered” employees, except those with a legally entitled accommodation.

Some things to note:

  • Covered employees must be fully vaccinated no later than December 8, 2021.

  • Applies to new, revised, renewed or modified federal contracts (subcontracts). It is not retroactive.

  • Applies to providers of services and construction companies, among others, but not providers of products.

  • The Guidance provides broad coverage for workplaces and employees:

    • Covers remote employees.

    • Covers any employee at a federal contractor (subcontractor) location where any employee is working “on or in connection with” a covered contract.

    • An employee works “on or in connection with” a covered contract if they perform duties necessary to the performance of the federal contract (subcontract), even if not performing the specific work called for in the contract. This could include HR, Legal, etc.

    • Covers full-time and part-time employees.

    • Covered employees and site visitors must follow CDC guidance on masking and physical distancing.

    • Covered contractors must review their covered employees’ documentation to prove vaccination status.

    • Covered contractors (subcontractors) must designate a person(s) to implement the Guidance and ensure employees and visitors comply with the requirements and monitor community transmission levels.

Be aware that several of these provisions may be challenged in the courts.

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