In alignment with President Biden’s Executive Order, safety requirements for federal contractors and subcontractors were released in this document. The guidance covers nearly any verbal or written contract, other than contracts/subcontracts for manufacturing of products only, or contracts under the Simplified Acquisition Threshold ($250,000). Agencies and contractors working with contracts not addressed by this guidance are encouraged to comply or place the clause in those contracts as well.
The guidance has a few key requirements:
- Full COVID-19 vaccination* by December 8, 2021** for all employees working on or in connection with a covered contract OR working at a covered contractor workplace (even if not working on or in connection with a covered contract), including remote workers. A covered contractor workplace is any contractor location a covered employee is likely to enter.
- Provide exceptions for religious/ADA accommodation. See COVID-19 toolkit for religious and ADA exemption forms.
- Mask/Social Distance in accordance with CDC community transmission guidelines as determined by the CDC COVID-19 Data Tracker County View at any location controlled by a covered contractor at which any employee of a covered contractor working on or in connection with a covered contract (this could include HR/Billing) is likely to be present.
- Designation of a person or persons to coordinate COVID-19 workplace safety efforts, including:
- Ensuring review of vaccination records
- Ensuring visitors and employees have clear, easily understood communications about COVID-19 safety requirements
- Checking the transmission level (see above) at least weekly
- Adjusting safety protocols upwards immediately (shift from low/moderate spread to high/substantial). If the spread decreases to low/moderate there is a two-week wait before adjusting protocol.
The covered contractor must view one of the following (digital copy OK) to verify vaccination:
- 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
- Other official documentation verifying vaccination with vaccine name, date(s), site or HCP.
Masks/physical distancing: Comply with published CDC guidance (including industry-specific requirements) to include:
- Masks must be worn properly (over mouth and nose), not have vents, nor be single-layer/non-light blocking. Some exceptions include: if requested, for identification; in an office with walls (ceiling to floor) and closed-door; for short periods of socially distancing while eating.) Some other situation-specific exceptions apply.
- In areas of high or substantial community transmission, fully vaccinated people must wear a mask in indoor settings.
- Fully vaccinated individuals do not need to physically distance no matter the transmission level.
- Individuals who are not fully vaccinated must wear a mask indoors and in certain outdoor settings regardless of the level of community transmission in the area.
- To the extent practicable, individuals who are not fully vaccinated should maintain a distance of at least six feet from others at all times, including in offices, conference rooms, and all other communal and workspaces.
Preparing your employees: It is important to prepare quickly if you are a federal contractor or subcontractor to ensure compliance while understanding the staffing issues that may arise from a mandate. View our vaccination planning tool, mandatory vaccination policy and other resources on our COVID-19 toolkit to assist you in decision-making. Education, communication and employee input are essential in developing and gaining commitment to the process.
* Fully vaccinated = 2 weeks after their second dose in a 2-dose series, such as the Pfizer or Moderna vaccines, or 2 weeks after a single-dose vaccine, such as Johnson & Johnson’s Janssen vaccine.