Guidance Published for Federal Contractor Vaccine Mandate

Vincent Jackson
Vincent Jackson

On September 24, 2021, the Safer Federal Workforce Task Force published guidelines for President Biden’s recently-announced COVID-19 vaccine mandate for federal contractors.  Here are the highlights:

  • “Covered contractor employees” of federal contractors must be fully vaccinated against COVID-19 no later than December 8, 2021.
    • People are considered fully vaccinated two weeks after they have received the second dose in a two-dose series, or two weeks after they have received a single-dose vaccine.
    • As a practical matter, employees must receive the second dose of a two-dose regimen by November 24, 2021—the day before Thanksgiving.
  • The term “covered contractor employee” is defined as: “any full-time or part-time employee of a covered contractor working on or in connection with a covered contract or working at a covered contractor workplace. This includes employees of covered contractors who are not themselves working on or in connection with a covered contract.”       Importantly, the mandate applies to all employees of a covered contractor, regardless of whether the employees are working on the federal contract or not.  Moreover, the mandate will also apply to employees who are working remotely from their homes, even if they never set foot in a federal workplace or their employer’s workplace.
  • Contractors may provide reasonable accommodations to employees who seek an exemption because of disability or sincerely held religious beliefs.
  • Contractors must review their employees’ documentation to prove vaccination status, and must require that their employees provide one of the following:
    • a copy of the record of immunization from a health care provider or pharmacy, a copy of the COVID-19 Vaccination Record Card (CDC Form MLS-319813_r, published on September 3, 2020);
    • a copy of medical records documenting the vaccination;
    • a copy of immunization records from a public health or State immunization information system; or
    • a copy of any other official documentation verifying vaccination with information on the vaccine name, date(s) of administration, and the name of health care professional or clinic site administering vaccine.

The guidance does not directly address how the mandate will be enforced, or what penalties contractors may face for noncompliance. 


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