New COVID-19 Requirements for Onsite Federal Contractors

Learn about the latest COVID-19 requirements for onsite federal contractors, part of Biden Administration's efforts to combat the Delta variant, including new vaccination and testing protocols.

New COVID-19 Requirements for Onsite Federal Contractors

The update from September 10, 2021, on COVID-19 vaccine and testing requirements for federal employees and onsite federal contractors introduces significant changes as part of the Biden administration's efforts to combat the spread of the COVID-19 Delta variant. The following highlights are key points:

Expanded COVID-19 Vaccine/Testing Requirements

The latest directive sets new operating regulations for various businesses and all federal contractors. Notably:

  1. Businesses With 100 or More Employees: The Occupational Safety and Health Administration (OSHA) is devising a rule requiring businesses housing 100+ employees to ensure each employee is fully vaccinated or submits to weekly COVID-19 testing.
  2. All Federal Contractors: The novel protocols mandate full vaccination against COVID-19 for employees working on or in connection with a federal contract, extending to all federal contractors, not just onsite. Unfortunately, the update does not provide a testing alternative.

New Safety Protocols for Federal Employees & Contractors

Besides mandatory vaccinations or testing, federal employees and contractors are required to comply with other safety measures. These include:

  • Vaccination Attestation: Federal employees and onsite contractors are obliged to confirm their vaccination status, typically via a Certification of Vaccination form.
  • Protocols for Unvaccinated Individuals: Individuals who haven't yet been vaccinated or disclosed their vaccination status must adhere to strict safety procedures. These procedures comprise mandatory mask-wearing, practicing physical distancing, submitting to regular COVID-19 tests, and adhering to travel restrictions.
  • Implementation Across Contractors: Considerations are underway to roll out these safety measures across all federal contractors.
  • Private Sector Encouragement: Interestingly, the administration is advocating for private sector employers to adopt these COVID-19 safety protocols.

Implications for Federal Contractors

With changes come implications, and for federal contractors, they involve a lot of preparation as they wait for detailed implementation which will differ by agency. The key points include:

  1. Awaiting Detailed Implementation: While they wait for comprehensive implementation plans, federal contractors should prepare for compliance.
  2. Role of the Safer Federal Workforce Task Force: The task force is providing key guidance to federal agencies on how to keep employees safe and maintain operations throughout the pandemic.
  3. Agency-Specific Plans: Each agency will have its unique approach based on the task force's model safety principles. So, contractors should keep an eye on updates to the COVID-19 plans from their customer agencies.

Resources and Guidance

The production of resources and guidelines that agencies and contractors can use to navigate this new phase include:

  1. Agency Model Safety Principles: The July 29, 2021 update of the COVID-19 Workplace Safety: Agency Model Safety Principles integrates the administration's latest actions.
  2. Testing Alternatives: Agencies have the agency to require proof of a negative COVID-19 test as an alternative to carrying out onsite testing for unvaccinated individuals.
  3. Monitoring and Preparation: Contractors should review the recent safety principles and FAQs, and stay ahead of updates from their respective customer agencies.


The Biden administration's modified COVID-19 protocols for federal employees and contractors signify a thorough response to the pandemic, with a focus on vaccination. Businesses and federal contractors are urged to closely follow these developments and prepare for compliance with the novel requirements. Led by a former GSA Schedule Reviewer, we offer top-notch GSA Schedule Consulting services.

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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