On September 9th, the President issued Executive Order 14042, which applies new rules - including vaccination mandates - to federal contractors. This rule is different and separate from (and stricter than) the OSHA rule that applies to large businesses; specifically, because this federal contractor mandate does NOT include a weekly testing option, and therefore is a true vaccination mandate. The rule defines "federal contractor" VERY broadly. As a result, the rule likely covers many industries. Implementing the rule's requirements will involve direct coordination with and support from each company's Human Resources departments. Sheppard Mullin's Government Contracts group has been working diligently in this area since the announcement of the Executive Order and related Task Force Guidance, and has developed an Executive Order 14042 Survival Guide that answers many of the questions related to the EO and Guidance. It also incorporates insights from Sheppard Mullin's Labor & Employment group regarding practical implications of the rule. Though much still is not known about how the EO and Guidance will be implemented, our Executive Order 14042 Survival Guide: An Analysis of What We Know, What We Think, and What We Don't Know about President Biden's COVID-19 Executive Order for Federal Contractors is here to help answer questions and provide additional insights.
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