Federal government contractors and subcontractors have been dealing with a steady stream of new FAQs and details regarding the COVID-19 safety requirements for federal contractors and subcontractors first announced by President Biden’s Executive Order 14042, Ensuring Adequate COVID Safety Protocols for Federal Contractors, and then issued by the Safer Federal Workforce Task Force (the “Task Force”). Our prior postings on all of those developments can be found hereherehere, here, and here.

On November 10, 2021, the Task Force issued updated Guidance and new FAQs regarding the COVID-19 requirements. As previously reported, a White House Fact Sheet issued on November 4, 2021 indicated that the December 8, 2021 deadline for covered contractor and subcontractor employees to be fully vaccinated would be extended. The updated Guidance issued on November 10, 2021 formally extends that deadline providing: “Covered contractor employees must be fully vaccinated no later than January 18, 202[2].”[1] This means covered contractor and subcontractor employees must receive their second dose of the Pfizer or Moderna vaccine, or single dose of Johnson & Johnson vaccine by January 4, 2022.

The Task Force also issued new and updated FAQs regarding the requirements. These include:

  • Announcing the availability of sample signage that contractors and subcontractors can post at entrances to announce safety requirements at their worksites.
  • Clarifying that when a covered contractor or subcontractor employee works at a federal government worksite (as opposed to working at home or at the contractor/subcontractor’s facility), the employee must still abide by the Guidance’s requirements.

We will continue to monitor and update our readers on new developments regarding the Task Force’s Guidance.

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[1] The updated Guidance contains a typographical error, stating the new vaccination deadline is January 18, 2021.

Photo of Guy Brenner Guy Brenner

Guy Brenner is a partner in the Labor & Employment Law Department and leads the Firm’s Washington, D.C. Labor & Employment practice. He is head of the Government Contractor Compliance Group and is co-head of the Non-Compete & Trade Secrets Group. He has…

Guy Brenner is a partner in the Labor & Employment Law Department and leads the Firm’s Washington, D.C. Labor & Employment practice. He is head of the Government Contractor Compliance Group and is co-head of the Non-Compete & Trade Secrets Group. He has extensive experience representing employers in both single-plaintiff and class action matters, as well as in arbitration proceedings. He also regularly assists federal government contractors with the many special employment-related compliance challenges they face.

Guy represents employers in all aspects of employment and labor litigation and counseling, with an emphasis on non-compete and trade secrets issues, medical and disability leave matters, employee/independent contractor classification issues, and the investigation and litigation of whistleblower claims. He assists employers in negotiating and drafting executive agreements and employee mobility agreements, including non-competition, non-solicit and non-disclosure agreements, and also conducts and supervises internal investigations. He also regularly advises clients on pay equity matters, including privileged pay equity analyses.

Guy advises federal government contractors and subcontractors all aspects of Office of Federal Contract Compliance Programs (OFCCP) regulations and requirements, including preparing affirmative action plans, responding to desk audits, and managing on-site audits.

Photo of Megan Childs Megan Childs

Megan Childs is an associate in the Labor Department and a member of the Employment Litigation & Arbitration Group.