(971) 645-4292

What the Federal Contractor Vaccine Mandate Means for Contractors

What the Federal Contractor Vaccine Mandate Means for Contractors


Pres. Biden issued an Executive Order requiring federal contractors with over 100 employees to have all employees vaccinated by December 8, 2021. It requires contractors with over 100 employees to have workers working on federal projects fully vaccinated and to keep records of those vaccinations. The actual mandate is working its way through the government bureaucracy before being issued by OSHA.

The mandate requires employers to:

  1. Vaccinate all workers working on federal contracts for COVID-19, except when the employee is legally entitled to an accommodation. This would include workers working with workers on a federal contract, even if they’re not on that contract. It could also include workers working from home.
  2. Comply with local masking and physical distancing protocols. Those protocols are based on CDC recommendations and sector-specific guidance at schools, health facilities, etc. Contractors must check the CDC’s county data site weekly to determine those protocols.
  3. Designate COVID-19 safety coordinator(s) to monitor the company’s safety efforts at covered workplaces.

The mandate applies to federal contracts or work orders that are entered into, modified, or extended on or after November 14, 2021, and that meet or exceed the simplified acquisition threshold, which is currently at $250,000.

Action steps for contractors

  • Compile a list of affected federal contracts
  • Assess which workers are working on or in connection with those contracts
  • Identify work locations subject to masking and distancing requirements
  • Determine which covered workers are fully vaccinated
  • Create a system to document proof of vaccination, including a backup system
  • Create contingency plans for those workers not vaccinated by December 8, 2021

Related Posts