HR Policy Association

HR Policy Explores Federal Contractor Vaccine Mandate Guidance

Published on: October 1, 2021

Authors: Gregory Hoff

Topics: COVID-19 Employer Issues, Employment Law

With a December 8 compliance deadline looming, the Association held a webinar examining the recently issued guidance implementing President Biden’s vaccine mandates for federal contractors, addressing open questions posed by the guidance.  The requirements are far-reaching, reflecting the administration's goal to get as many people vaccinated as possible.



“At this point, there are more questions than answers,” noted Roger King, Senior Labor and Employment Counsel.  Mr. King emphasized that requirements under the issued guidance are intentionally broad so as to cover as many workers as possible.

Mr. King was joined by other HR Policy staff to examine each component of the guidance and requirements for federal contractors, including:

  • Which contracts are covered;
  • Which employees and worksites are covered;
  • How “fully vaccinated” is defined under the guidance, and what is acceptable proof;
  • Masking and physical distancing requirements;
  • Exemptions and accommodations; and
  • Conflict with state and local laws.

HR Policy addressed the membership's open questions related to the guidance, including regarding religious and disability exemptions and the associated reasonable accommodation process, the scope of coverage for both contracts and employees, and vaccine recordkeeping. 

In a September 29 briefing by the Office of Management and Budget that offered few specifics, the agency reiterated that the goal of the administration is to cover as many workers as possible, and that there will be no extension of the initial December 8th compliance deadline. Notably, officials did acknowledge that employers will not be expected to resolve all outstanding disability and religious exemption requests and associated reasonable accommodations ahead of this deadline. 

OSHA requirement for all employers expected soon:  Vaccine mandates are continuing to increase at the federal level—with requirements for larger private sector employers via an Emergency Temporary Standard issued by OSHA expected within weeks—and at the state level, such as New York requiring vaccination for certain sectors of the workforce.  The New York vaccine mandates have resulted in a number of terminations and resignations, highlighting the talent retention issues facing the growing number of employers subject to such requirements.  HR Policy is continuing to engage with federal officials to raise issues facing employers, and we will be hosting more calls to further discuss the employer implications of vaccine mandates. 

Gregory Hoff

Associate Counsel, HR Policy Association

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