November 2023



Vaccine mandate for federal contractors delayed


Author: ADP Admin/Monday, November 29, 2021/Categories: Bulletin News, Compliance Corner , Federal Compliance Update

President Biden has announced that federal contractors and subcontractors will have until Jan. 18, 2022 to ensure that all covered employees are fully vaccinated for COVID-19.


In early September, President Biden announced an executive order that requires COVID-19 vaccination for contractors that do business with the federal government. The executive order also requires contractors to comply with guidance published by the Safer Federal Workforce Task Force. On September 24, 2021, the task force released guidance that indicated contractors must ensure that all covered employees are fully vaccinated for COVID-19 no later than December 8, 2021.

New Deadline:

In updated guidance, the Task Force says federal contractors and subcontractors will have until Jan. 18, 2022 to ensure that all covered employees are fully vaccinated. Under the guidance, individuals are considered fully vaccinated for COVID-19 two weeks after they have received the second dose in a two-dose series, or two weeks after they have received a single-dose vaccine.

After Jan. 18, 2022, all covered employees must be fully vaccinated by the first day of performance on a newly awarded covered contract, and by the first day of performance on an exercised option or extended or renewed contract when the clause has been incorporated into the covered contract.

Documentation of Vaccination:

The covered contractor must review its covered employees’ documentation to prove vaccination status. Covered contractors must require that covered employees show or provide one of the following documents:

  • A copy of the record of immunization from a healthcare provider or pharmacy,
  • A copy of the COVID-19 Vaccination Record Card,
  • A copy of immunization records from a public health or state immunization information system,
  • A copy of medical records documenting the vaccination, or
  • A copy of any other official documentation verifying vaccination with information on the vaccine name, date(s) of administration, and the name of the healthcare professional or clinic site administering vaccine.

Covered contractors may allow employees to show or provide to their employer a digital copy of such records.


A covered contractor may be required to provide an accommodation to covered employees who communicate that they are not vaccinated against COVID-19 because of a disability or because of a sincerely held religious belief, practice, or observance. A covered contractor should review and consider what, if any, accommodation it must offer. Requests for “medical accommodation” or “medical exceptions” should be treated as requests for a disability accommodation.


The Task Force has published FAQs to assist in understanding the guidelines.

Compliance Recommendations:

Covered federal contractors should review the updated guidance in full and ensure compliance by the deadline. Please contact your dedicated service professional with any questions.

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Tags: 12/02/21

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