The ​OMB held a conference call on 9/15/2021for Contractor Reps regarding the Executive Order signed on 9/9/2021 that will mandate vaccination for federal contractors. I attended the conference and captured the following notes that I wanted to share with you to help you prepare.

First, additional OMB Guidance will be forthcoming by 9/24/2021. Look for it at their website: The guidance will provide:

  • Additional guidance and definitions
  • The timeline for implementation
  • What the acceptable vaccination documentation is that will substantiate proof of vaccination
  • Definitions of Covered Worksite and Employees
    • Will clarify whether remote workers working from home are covered.

The Executive Order will become operational effective 10/15/2021 for contractors and will apply to all contractors (small and large alike) who have a contract awarded, extended, or option exercised after 10/15/2021, AND where the contract is:

  • More than $250,000 in value
  • NOT performed overseas
  • NOT for product purchases only

The Executive order applies to all prime contractor and subcontractor covered employees working on, or in connection with, a government contract (except for subcontractors that purely provide products).

Federal Contractor responsibilities will include three things:

  1. All covered employees must be fully vaccinated
  2. All covered employees must comply with social distancing and masking guidelines
  3. The Contractor must designate a person to be responsible for ensuring compliance

Note that Federal Contractors will need to maintain proof of their compliance or risk paying a penalty of $14,000 per incidence.

That’s the gist of the Executive Order for now. Make sure to go to for the most current information.

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