Federal Task Force announces COVID-19 guidance for Federal Contractors and Subcontractors

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.


** Current interpretation is that contractor compliance is only required once the clause is added to a contract. The clause will be required for all contracts after November 14, 2021, some between October 15 and November 1, and contracts prior to October 15 when an option or extension is exercised; however, agencies and contractors are encouraged to include and comply earlier.)