COVID-19 Vaccination Mandate for Federal Contractors

Written October 4, 2021

Categories: First to Know, Human Resources

On September 9, 2021, President Biden issued an Executive Order announcing a vaccine mandate for federal workers and federal contractors. In support of this, the Federal Safer Workforce Task Force released new Guidance on September 24, 2021 to address how the vaccine mandates in the EO will be implemented for federal workers and federal contractors. Printing operations, regardless of size, that have contracts with the federal government to provide printed matter or other services are subject to the new mandate.

The federal contractor mandate applies to the following businesses:

  • Companies that have a contract for services (this covers printing contracts) – this includes a subcontract that comes from a federal services contract.
  • Companies of any size – there is no minimum headcount.
  • Companies with employees that work in the United States.
  • Other types of contracts covered: Construction, leasehold interest in real property for services, procurement, concessions, or federal property and lands.
The vaccine mandate does not apply in the following circumstances:
  • Federal contracts that are only for the provision of products.
  • Contracts with Native American tribes.
  • Contracts or subcontracts at or below the “simplified acquisition threshold”, which is $250,000 for most contacts.
  • Employees working outside of the U.S., although employees working in the U.S. are covered by the mandate.

Employees of companies covered by qualifying contracts are required to be fully vaccinated by December 8, 2021 unless they qualify for an exemption. This includes all employees working in the United States, whether at a federal worksite, the company facility, from home, or a remote location.

The approved exemptions are:

  • Sincerely held religious belief
  • Medical condition
  • Disability

Those employees who are not fully vaccinated due to a qualifying exemption must be accommodated by the federal contractor unless such accommodation presents an undue hardship. In addition, non-vaccinated employees must follow the current masking and distancing protocols set forth by the Centers for Disease Control and Prevention (CDC).

In addition to the vaccination requirement, all federal contractors must have all people at their workplace comply with the CDC guidelines, even if they are not employees of the organization. In areas experiencing high community transmission of COVID-19, federal contractors must institute mandatory masking indoors, irrespective of vaccination status.

All contracts that are subject to extension/renewal, and all new contracts, will have the mandatory vaccination provisions included in those renewed or new contracts as of October 15 and November 14, respectively.

The federal contractor must designate one or more individuals to coordinate the implementation of the guidance. The designated individuals will be responsible for implementing the vaccine mandates, communicating with the employees about the requirements, and monitoring employee compliance.

For more information, please contact PRINTING United Alliance’s Government Affairs Department at govtaffairs@printing.org or Adriane Harrison, VP of Human Relations Consulting at aharrison@printing.org.