Federal government contractors and subcontractors are facing a deadline of Dec. 8 to get their employees fully vaccinated against the COVID-19 virus – subject to a list of exceptions that include medical conditions and religious beliefs – with an additional 60-day extension of the compliance window possible in the case of “urgent” contract needs.

Those are the top-line takeaways from guidance issued on September 24 by the White House’s Safer Federal Workforce Task Force. The task force’s guidance for contractors stems from President Biden’s executive order issued earlier this month which gave Federal employees until November 22 to be fully vaccinated – with limited exceptions – against COVID-19.

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The Safer Federal Workforce Task Force is led by the White House COVID-19 Response Team, along with the General Services Administration and the Office of Personnel Management.

The task force’s new guidance for Federal contractors states that “all covered contractor employees” must be fully vaccinated by December 8, unless the employee is legally entitled to an accommodation.

In that case, the task force said that accommodations could include “a disability (which would include medical conditions) or because of a sincerely held religious belief, practice, or observance.” If those events occur, a “covered contractor should review and consider what, if any, accommodation it must offer,” the task force said, adding that the requests for “medical accommodation” or “medical exceptions” should be treated as requests for disability accommodation.

The contractor guidance also allows contractors more time to make sure that employees are fully vaccinated in the event that a Federal agency head approves an exception in the case of an “urgent, mission-critical need.”

“Should a Federal agency have an urgent, mission-critical need for a covered contractor to have covered contractor employees begin work on a covered contract or at a covered workplace before becoming fully vaccinated, the agency head may approve an exception for the covered contractor —in the case of such limited exceptions, the covered contractor must ensure these covered contractor employees are fully vaccinated within 60 days of beginning work on a covered contract or at a covered workplace,” the task force guidance says.

In that event, the contractor “must further ensure that such employees comply with masking and physical distancing requirements for not fully vaccinated individuals in covered workplaces prior to being fully vaccinated,” the task force said.

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John Curran
John Curran
John Curran is MeriTalk's Managing Editor covering the intersection of government and technology.