Confused About COVID-19 Safety Protocols/Vaccine Requirements?

Get the latest updates on COVID-19 vaccine mandates for federal contractors, understanding the implications of the nationwide injunction, and future changes in compliance requirements.

Title: Confused About COVID-19 Safety Protocols/Vaccine Requirements?

As of December 7, 2021, a noteworthy development regarding the COVID-19 vaccine mandate for federal contractors has emerged. A nationwide injunction has been issued which halts enforcement of the vaccine mandate across all US states and territories. Aid us in delving deeper into this issue, particularly how it impacts GSA Schedule Contract holders and other federal contractors.

Recent Developments:

We have seen some major changes in recent times.

Nationwide Injunction on Vaccine Mandate (12/7/2021 Update):





Vaccine Mandate Blocked in Three States (11/30/2021 Update):

Recently, a federal judge put a temporary stop on the COVID-19 vaccine mandate for federal contractors in Kentucky, Ohio, and Tennessee.

Vaccination Deadline Extension (11/4/2021 Update):

The deadline for federal contractors to follow COVID-19 Safety Protocols (FAR clause 52.223-99) was rolled over to January 4, 2022.

GSA Industry Session Recording Released (10/25/2021 Update):

In an industry session, the GSA discussed COVID-19 safety protocols for federal contractors, addressing industry questions and providing clarifications.

Key Points to Understand

Let's further delve into the effects of these developments.

FAR Clause 52.223-99 Requirements:

Originally, this clause implied that federal contractors had to comply with COVID-19 safety protocols, which includes a vaccine mandate.

Impact on GSA Schedule Contract Holders:

Contractors who refused the Refresh 8 mass modification (A837) were removed from GSA’s eLibrary and Advantage websites. With this court injunction, these contractors are now visible again!

Implications for Federal Contractors:

Thanks to the recent injunction, federal contractors don't currently have to enforce the vaccine mandate. Nevertheless, being informed about potential changes and new updates is of utmost relevance.

Looking ahead, the requirement to enforce the vaccine mandate might be subject to change due to further legal and administrative actions. Regular updates from GSA and other federal agencies should be closely monitored by contractors to comply with any future changes in COVID-19 safety protocols and mandates.


For updates and details about the mandate and its enforcement, contractors can refer to the Executive Order on Ensuring Adequate COVID Safety Protocols for Federal Contractors, the Safer Federal Workforce Task Force guidelines, and the GSA’s COVID-19 webpage.


Considering the fluid nature of this situation, it's pivotal for GSA Schedule Contract holders and federal contractors to keep abreast of the latest updates related to COVID-19 safety protocols and vaccine requirements. The suspension of the mandate could be temporary, with future updates potentially altering the established compliance requirements. Fortunately, you can rely on our GSA Schedule Consulting services, led by a former GSA Schedule Reviewer.

Pedro has extensive background as a Contracting Officer and Contract Specialist, has worked across seven federal agencies, managing contracts totaling over $1 billion in the professional and tech sectors. His notable tenure includes serving with the DoD/DARPA during the inception of their robotics program. Additionally, he played a pivotal role in initiating the Cyber Special Item Number (SIN) within the GSA's IT Schedule 70 as a Team Lead. After graduating from Harvard, he started Blackfyre to help you win your next contract.

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