Justin A. Chiarodo and Stephanie M. Harden
Yesterday, November 1, 2021, the Safer Federal Workforce Task Force issued significant new guidance for contractors implementing vaccine mandates. The two key takeaways are: (1) contractors are not required to terminate unvaccinated employees immediately when the mandate goes into effect on December 8, and (2) federal agencies should not terminate contracts if a contractor is actively working toward compliance, even if the contractor faces challenges to achieving full compliance. The full updated FAQ is available on the Safer Federal Workforce Task Force website.
Are contractors still required to mandate vaccination by December 8?
Yes, covered contractors are still required to mandate that employees get vaccinated by December 8. However, rather than terminate noncompliant employees after the December 8 deadline, contractors should “determine the appropriate means of enforcement” for their employees.
Continue reading “Government Provides New Compliance Flexibility under Contractor Vaccine Mandate”
Justin A. Chiarodo and Albert B. Krachman
Answering some questions and raising others, the Safer Federal Workforce Task Force issued its highly anticipated COVID-19 Workplace Safety: Guidance for Federal Contractors and Subcontractors on Friday, September 24. The Guidance follows the president’s September 9, 2021, Executive Order (“EO”), which we summarized in FAQ: Government Contractor COVID Safeguards Executive Order.
In short: a broad vaccine mandate for employees of government contractors is coming. But the exact details on application, exemptions, and compliance remain unclear. New rules due by October 8, 2021, should better address those questions. Adding to this uncertainty, the Guidance encourages individual agencies to issue their own (potentially broader) guidance. That said, we can infer a lot from Friday’s guidance.
Continue reading “Breaking Down the COVID-19 Safety Guidance for Government Contractors and Subcontractors: What We Know, What We Don’t, and What’s Next”