The moving target for the COVID-19 vaccine mandate is either good news for some or just an extension of the looming headache. While only a small percentage of the cleared workforce are threatening to quit in response to the mandate, it’s still more than the industry wants to lose. The good news is that the White House has now adjusted the deadline for federal contractors. What was once December 8 is now January 4. Happy holiday season to the federal contractors. The new deadline was intended to simplify compliance for those contractors who support the federal government AND industry. Large companies especially can have a more uniform implementation process.

OSHA Guidelines the Same for Federal Contractors?

This updated timeline for federal contractors lines up with the standards outlined in OSHA’s emergency temporary standard (ETS) that mandates the COVID-19 vaccine for companies with 100 or more employees. Now, those falling under the OSHA rule and/or the federal contractor requirement need to have their final vaccine dose by January 4. Keep in mind that while the deadline was updated, there are still differences with how the private sector can choose to implement OSHA’s vaccine guidance compared to the federal mandate for “covered contractors.” For those doing business with the federal government, there isn’t an option to opt out of the vaccine and submit to weekly testing. However, employees who have an approved medical or religious exemption, there are options to follow social distancing, testing, and masking guidelines.

Progress OVer Perfection

And for contractors stressing about meeting the mandate, the Administration has made it clear that while the requirements are clear, they do support “good faith” efforts to get to the end goal – which is a vaccinated workforce. However, while that may seem like a lenient message, the federal government has made it clear that contractors should follow the same path of counseling, suspension, and eventual termination if noncompliance is the continued response from an employee.

What about the Federal Employee

Federal employees still have until November 22 to be fully vaccinated – regardless of their location. Remote workers or in-office staff alike need to have their second shot no later than November 8. Any medical or religious exemptions also need to be filed by November 8. Of course, it wouldn’t be life as a federal employee if you didn’t have to fill out another form to tell the government in the same or new way that you have indeed been vaccinated. It’s like all the redundant trainings – just add the myriad of vaccination forms and processes to the list of things that drain the life out of federal employees.

Life on the OUtside as a 1099?

And before you think of making the leap to a 1099 status to avoid the mandate, you may want to reconsider if that’s your only reasoning. Don’t get me wrong. I highly recommend the 1099 defense contracting life if you can make it work for you. But don’t try to duck out of the mandate this way, as the Guidance for Federal Contractors and Subcontractors explains that as a “covered contractor” in the chain, you have to meet the requirements outlined. Future contracts will have the language detailed specifically to avoid any questions. So whether you work remotely from a local park or in a federal facility, a covered contractor has to abide by the current deadline, which is now January 4.


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Jillian Hamilton has worked in a variety of Program Management roles for multiple Federal Government contractors. She has helped manage projects in training and IT. She received her Bachelors degree in Business with an emphasis in Marketing from Penn State University and her MBA from the University of Phoenix.