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Federal contractors, subcontractors must vaccinate workers by December 8

October 2021 employment law letter
Authors: 
Grant T. Collins, Felhaber Larson

The White House’s Safer Federal Workforce Task Force recently released new vaccination guidance for federal contractors and subcontractors. Under the guidelines, employees of federal contractors (and subcontractors) must be fully vaccinated for COVID-19 or request and receive a medical or religious accommodation by December 8, 2021. In addition, beginning on November 14, the vaccination requirement must be added to any “new” federal contract and any existing federal contract that is “renewed.” Beginning on October 15, however, federal agencies will be “encouraged” to include the vaccine requirement in their federal contracts.

How we got here

On September 9, President Joe Biden announced “hard” vaccine mandates for healthcare workers and federal contractors, meaning their employees must get the shots or request and receive a medical or religious accommodation (see “Biden’s COVID-19 action plan toggles between hard, soft vaccine mandates” in our November 2021 issue). Unlike with a “soft” mandate, testing in lieu of vaccination is not an option under the hard approach.

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