Federal Contractor Vaccination Compliance Deadline Moved to Jan. 18, 2022

On November 10, the Safer Federal Workforce Task Force released an updated Guidance (which you can access here). The new date for compliance with the vaccine mandate is Jan. 18, 2022.

Here is the relevant paragraph:

Covered contractors must ensure that all covered contractor employees are fully vaccinated for COVID-19, unless the employee is legally entitled to an accommodation. Covered contractor employees must be fully vaccinated no later than January 18, 2022. After that date, all covered contractor employees must be fully vaccinated by the first day of the period of performance on a newly awarded covered contract, and by the first day of the period of performance on an exercised option or extended or renewed contract when the clause has been incorporated into the covered contract.

The original date had been set at December 8, 2021.

Remember that the definition of fully vaccinated is 2 weeks after the second shot in a 2-shot series or the first shot in a 1-shot series. Accordingly, the covered contractor employee will want to have their final shot by January 4, 2022, so that they can be “fully vaccinated” by two weeks later – Jan. 18.

If your company is a covered contractor, remember that your date for compliance will depend on whether the clause requiring vaccinations for employees (who are not exempt for medical or religious purposes) is in your contract right now. If yes, then it appears that the date by which they need to be vaccinated is Jan. 18, per the linked document. If not, then the vaccination compliance date will be the first day of the period of performance on an exercised option or extension/renewal once the clause is incorporated.

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