As we have previously shared, only those employers that enter into a contract or subcontract, or received an extension or had an option exercised on an existing contract, with the new mandate clause entitled “Ensuring Adequate Covid-19 Safety Protocols for Federal Contractors,” will be required to comply with the vaccine mandate for federal contractors. Many companies have already received new or amended contracts, and others have received notices from government contracting agencies informing them of the agency’s intention to make a bilateral modification (i.e., a proposed amendment by the agency) to existing contracts. Notably, we have seen these bilateral modifications being made to existing contracts that would not otherwise be covered.

If you operate one of these businesses, the following are three resources to help you review your contracts:

Resource 1: Federal Acquisition Regulation (FAR) clause

This is the clause that may appear in your federal contract or subcontract. If it does (or you have the option to, and agree to, modify a current contract), the vaccine mandate for federal contractors applies to your business.

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Resource 2: Summary of requirements and steps to get ready for compliance

This article covers the requirements and details of the vaccine mandate for federal contractors as well as next steps to help you prepare for compliance.

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Resource 3: Stay abreast of changes via updated FAQ

Review the updated Frequently Asked Questions (FAQ) document regarding application and implementation of the vaccine mandate, including guidance on mask-wearing and visitor restrictions.

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For more information on this topic, contact a member of our Labor, Employment & Immigration Law Practice Group.