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Federal Contractor COVID Vaccination Requirements Clarified

The White House recently issued an executive order that federal contractors must be vaccinated against COVID-19 by Dec.8, 2021. After December 8, covered employees, including those who work outside or work remotely, must be fully vaccinated by the first day of the period of performance on a newly awarded covered contract, and by the first day of the period of performance on an exercised option or extended or renewed contract when the clause has been incorporated into the covered contract. If needed, limited 60-day exceptions may be granted by agency heads to begin work in support of “urgent, mission-critical need” for a covered employees to begin work on a contract or at a worksite before becoming fully vaccinated.

Details and guidance on the requirement were issued by the Safer Federal Workforce Task Force that provided clarification on the mandate and its related safety protocols.

There are three key takeaways include:

1. Federal contractor employees with the exception of those with limited exceptions are required full vaccination.

2. Mask and physical distancing is mandatory at contractor worksites for employees, visitors and others.

3. Contractors must designate a COVID safety Coordinator or committee to steer workplace safety efforts.

To demonstrate compliance, contractors are required to obtain proof of employee vaccination status by providing proof of vaccination status through one of the forms of documentation which include;

· a copy of the record of immunization from a health care provider or pharmacy;

· a copy of the COVID-19 Vaccination Record Card;

· 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.

To ensure successfully transition and compliance with the new mandate, federal contractors should communicate the new requirements their workforce and also determine how proof of vaccination will be collected, stored and accessed. For additional information and guidance, employers may reference the Workplace Vaccination Program guidelines published on the CDC webpage.


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