New Vaccine Requirements for Federal ContractorsThe Biden administration recently announced that “every federal government employee and onsite contractor will be asked to attest to their vaccination status,” and that anyone who “does not attest to being fully vaccinated will be required to wear a mask on the job no matter their geographic location, physically distance from all other employees and visitors, comply with a weekly or twice weekly screening testing requirement, and be subject to restrictions on official travel.”

To help carry out this new policy, the Safer Federal Workforce Task Force recently published Agency Model Safety Principles for executive departments and agencies for their COVID-19 safety plans. Among other things, the Agency Model Safety Principles provide that:

  • “Federal agencies need to ask about the vaccination status of Federal employees and onsite contractors—employees and onsite contractors must sign an attestation confirming their vaccination status, or they will be treated as not fully vaccinated for purposes of safety protocols.”
  • Federal agencies must “establish a program to test not fully vaccinated Federal employees and onsite contractors weekly or twice-weekly.”
  • “Fully vaccinated Federal employees and onsite contractors do not need to physically distance or participate in weekly screening testing, and are not subject to any Government-wide restrictions on official travel (although agency travel policies still apply).” However, in “areas of high or substantial transmission, they need to wear a mask in public indoor settings in Federal buildings,” but in “areas of low or moderate transmission, they do not need to wear a mask.” (emphasis added)
  • “Those Federal employees and onsite contractors who are not fully vaccinated or decline to provide their vaccination status must wear a mask, physically distance, and comply with a weekly or twice-weekly screening testing requirement, and are subject to Government-wide restrictions on official travel.” These requirements apply whether indoor or outdoor or whether in areas of low, moderate, or high transmission.
  • “Employees and onsite contractors must attest to the truthfulness of the response they provide. If an employee or onsite contractor chooses not to provide a response, they will be treated as not fully vaccinated for the purposes of these protocols.”

While the current mandate for federal contractors pertains to employees who work onsite at federal facilities, the White House announced that “President Biden is directing his team to take steps to apply similar standards to all federal contractors.”

If you have any questions about how this new policy impacts your company and its employees, please do not hesitate to contact Aron Beezley or Patrick Quigley.

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Photo of Aron C. Beezley Aron C. Beezley

Aron Beezley is the co-leader of Bradley’s nationally ranked Government Contracts Practice Group. Ranked nationally himself in Government Contracts Law by ChambersLaw360Benchmark Litigation, and Super Lawyers, Aron’s vast experience includes representation of government contractors in numerous industries…

Aron Beezley is the co-leader of Bradley’s nationally ranked Government Contracts Practice Group. Ranked nationally himself in Government Contracts Law by ChambersLaw360Benchmark Litigation, and Super Lawyers, Aron’s vast experience includes representation of government contractors in numerous industries and in all aspects of the government-contracting process, including negotiation, award, performance and termination.

Photo of Patrick R. Quigley Patrick R. Quigley

Patrick Quigley’s practice is focused on litigating bid protests, contract claims, prime/subcontractor disputes, and small business size protests/appeals at the Government Accountability Office, U.S. Court of Federal Claims, boards of contract appeals, federal agencies, the Small Business Administration, and state courts. He…

Patrick Quigley’s practice is focused on litigating bid protests, contract claims, prime/subcontractor disputes, and small business size protests/appeals at the Government Accountability Office, U.S. Court of Federal Claims, boards of contract appeals, federal agencies, the Small Business Administration, and state courts. He conducts internal investigations and defends clients in False Claims Act litigation, government investigations, and suspension and debarment actions. Patrick conducts due diligence reviews of and advises on the government-contract aspects of business transactions, and counsels on procurement law compliance, federal employee ethics rules, teaming agreements, and conflict-of-interest mitigation plans. View articles by Patrick.