EEO Compliance Dispatch

As federal contractors grapple with all the uncertainties around the vaccine mandate, the White House’s Safer Federal Workforce Task Force has issued additional FAQs supporting its Guidance for contractors. (For a more thorough review of the Guidance, see our prior bulletin.)

The new FAQs are all in the section on Vaccination and Safety Protocols. The main points provided by the Task Force include the following:

• If an accommodation request is denied, the covered contractor should establish a timeline for the covered contractor employee “to promptly become fully vaccinated.”
• Covered contractors may grant covered contractor employees an extension to the vaccination deadline “in some limited circumstances,” such as when an employee has recently received monoclonal antibodies or convalescent plasma for COVID-19 treatment or is recovering from a current SARS-CoV-2 infection. (The FAQs list the circumstances under which vaccination should be delayed, according to guidance from the Centers for Disease Control and Prevention.)
• If a contractor extends the deadline for a covered contractor employee to be vaccinated for an approved reason, it “should require that individual to become fully vaccinated promptly after clinical considerations no longer recommend delay.”
• COVID-19 vaccination is recommended for people trying to get pregnant as well as for those who are pregnant or breastfeeding. “However, a covered contractor may allow a covered contractor employee to delay vaccination based on the contractor employee’s particular medical circumstances, consistent with the covered contractor’s process for reviewing delay requests.”
• Recent administration of another vaccine, such as the flu shot, does not justify a delay in receiving the COVID-19 vaccine. In fact, the COVID-19 vaccine and other vaccines may be administered at the same time.

We will continue to post additional information as updates become available.