Federal Contractors’ Covid-19 Vaccination Requirements Updated to January 2022

Read an update to the below story: Enforcement of Covid-19 Vaccination Requirement for Federal Contractors Remain Enjoined


The Safer Federal Workforce Task Force updated its “COVID-19 Workplace Safety: Guidance for Federal Contractors and Subcontractors”, changing the date by which covered contractor employees must be fully vaccinated from December 8, 2021 to January 18, 2022. This change was expected after the Biden administration announced it was pushing back the deadline for federal contractors to align with OSHA’s vaccination and testing requirements deadline for private sector companies with 100 or more workers.

This update means that all covered contractor employees must receive their final COVID-19 vaccine dose by January 4, 2022, unless an accommodation has been provided because of a disability (including medical conditions) or a sincerely held religious belief, practice, or observance. To meet this deadline, a first dose of the Moderna vaccine must be received by December 7, 2021, a first dose of the Pfizer vaccine must be received by December 14, 2021, or the single dose of Johnson & Johnson must be received by January 4, 2022.

Additionally, Frequently Asked Questions for federal contractors were updated to include additional information on:

  • sample signage that covered contractors can post at entrances to their workplaces to provide information on safety protocols;
  • circumstances that the CDC recommends delaying vaccination for COVID-19; and
  • applicability of the workplace safety protocols enumerated in the Task Force Guidance for Federal Contractors and Subcontractors irrespective of whether the work is performed at a covered contractor workplace or at a federal workplace.

For more information, please access the full guidance.

FH+H’s Government Contracts practice group will continue to analyze new developments regarding the federal contractor COVID-19 vaccination requirements, and our attorneys are available to discuss specific client questions.

Note: The information contained on this page does not constitute legal advice, and reading the information does not automatically start an attorney-client relationship. The details are meant to serve as general information, and are not comprehensive of all legal requirements or situations.


About the Authors

Marlena Ewald is a Senior Associate with FH+H who has a variety of experience counseling government contractors on corporate, transactional, and regulatory matters.

Lucinda (Lucy) Hendrix is a fall associate at FH+H who is a 3L at George Washington University Law School. She has experience clerking and interning in the government sector.

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