On November 10, 2021, the Safer Federal Workforce Task Force (“SFWTF”) updated its Guidance for Federal Contractors and Subcontractors and its FAQs for contractors subject to the new vaccination mandate.
Notably, the update includes an extension for the deadline to be “fully vaccinated” for COVID-19. The initial deadline of December 8, 2021 has been extended to January 18.
As a reminder, the definition of “fully vaccinated” still includes the requirement that at least two weeks have passed since the employee received the final dose of a two-dose vaccine or the only dose of a single dose vaccine.
As background, the Safer Federal Workforce Task Force (Task Force) published its initial Guidance for Federal Contractors and Subcontractors (Guidance) on Friday, September 24, 2021, in response to President Biden’s Executive Order 14042, Ensuring Adequate COVID Safety Protocols for Federal Contractors (“EO”). The Guidance provides definitions, three sections of contractor guidance, and a host of questions and answers to assist contractors in implementing the President’s vaccine mandate and workplace safety measures.
The Guidance is broad and the vaccine mandate applies to employees that are “working on or in connection with a covered contract or working at a covered contractor workplace,” which includes remote workers and others not directly working on a government contract (i.e., HR, billing, legal).
The Guidance does not provide an exception for employees with a negative COVID-19 test result or that have had a prior COVID-19 infection. The Guidance also includes masking and physical distancing requirements and a requirement that “[c]overed contractors shall designate a person or persons to coordinate implementation of and compliance with this Guidance.”
Employer Action Items:
- Familiarize yourself with the requirements and continue compliance efforts.
- Contact your Valent consultant for a sample vaccination policy and reasonable accommodations forms.
- Determine whether you need to renegotiate with your unions regarding the deadline extension.
For recent Compliance Check blog posts, visit: https://www.valentgroup.com/category/employee-benefits/compliance-check/
This blog and its contents are not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.