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NEW DEADLINE: Vaccine Mandates for Federal and State Government Contractors and Subcontractors

Below is an article updated in late October on the new vaccine deadlines for federal contractors.  On November 4, President Biden issued an updated timeline to align with the New OSHA requirements for employers with over 100 employees.  Federal contractors, as stated below, were originally required to be fully vaccinated no later than December 8th That deadline has been extended to January 4th.  Read the Nov 4 White House Memo here.

Covid-19 guidance for federal government contractors has been published:  Government contractors working on or in connection with a federal contract need to be vaccinated (or have a religious/medical exemption).  Unlike the State Proclamation, the new federal guidance includes employees who work remotely or never go on-site to a federal building. There are no testing-related alternatives for the state nor local mandates.  Within the guidance from both the state and federal governments are important details every employer needs to review.  

Federal Government – Key Points

  • Executive Order 14042 on September 9 incorporates vaccine and mask requirements into federal contracts over simplified acquisition threshold (currently $250,000) and subcontracts. Guidance was published on Sept 24. 

    October 1 UPDATE
    : DoD and GSA issued Agency Deviations linked here and here to implement the Executive Order.

    October 13 UPDATE:  GSA offered an industry training. Slides and recording offered here



  • October 21 UPDATE:  To view a side-by-side chart of how each agency is rolling out the vaccine mandate, see this handy chart of Agency Class Deviations.


    • WHO: Employees are required to be vaccinated (or have a religious/medical exemption) if they work on or in connection with a covered contract or subcontract (including remote or outdoor workers).
    • WHO ELSE: It further extends the mandate to employees who work at a covered contractor workplace if the employee is likely to be present during the period of performance for a covered contract (i.e. they all park in the same parking garage or share a breakroom).
    • TIMING: Contractors should watch for when their federal customers incorporate the clauses into existing or new contracts. December 8th is the mandate’s official start. Watch for a contract modification or for the new language to be in contracts awarded in mid-October moving forward.  Employees entering federal facilities are already being asked to provide proof of vaccination in many cases.  See agency deviations (linked above) for updated timing.
    • MASKING: The guidance also requires covered contractors to ensure all employees are visitors are masked up if there are high rates of infection in the community. They provide a website to check that.  Non-vaccinated people always need to mask up.
  • This website has a helpful “what’s new” tab as well as an FAQ

State Government – Key Points

  • Governor Inslee issued Proclamation 21-14 on August 20th that prohibits on-site “workers” (i.e. independent contractors) from engaging in work for a state agency after October 18 if the worker has not been fully vaccinated.  Guidance has been issued here that includes sample letters of what your contracting officer will flow down and templates for exemptions and more.
  • Religious / medical exemptions are available.
  • DES identified statewide master contracts for goods and services that require on-site work. See vendor list here published on September 28. 

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