On Friday, the White House’s Safer Federal Workforce Task Force released new guidance for vaccinating federal contractors and subcontractors.  Per the guidelines, employees of federal contractors (and subcontractors) have until Dec. 8, 2021 to be “fully vaccinated” or request and receive a medical or religious accommodation.

The Guidelines provide that, beginning on Nov. 14, the vaccination requirement must be added to any “new” federal contract and any existing federal contract that is “renewed.” However, federal agencies are “strongly encouraged” to include the vaccine requirement in their federal contracts beginning on or before Oct. 15.  Agencies and covered contractors are also “strongly encouraged” to incorporate the vaccination requirement into non-covered contracts and subcontracts.


On Sept. 9, President Biden announced “hard” vaccine mandates for healthcare workers and federal contractors. A “hard” mandate means employees must receive the vaccine, or a medical or religious accommodation. Unlike a “soft” mandate, testing in lieu of vaccination is not an option. Remember, President Biden also announced that OSHA would issue a “soft” mandate for employers with 100+ employees.

The Guidance released on Friday does not address the OSHA standard or the CMS rule for healthcare workers. These rules are still being drafted.  That said, the Task Force’s Guidance offers insights into how the OSHA and CMS rules may be drafted.

Testing Is Not an Option

As noted above, employees of federal contractors do not have the option of “testing” in lieu of receiving the COVID-19 vaccine.  Instead, on or before December 8, 2021, employees of federal contractors (and subcontractors) must be either: (a) fu