A month ago, President Joe Biden issued an executive order mandating COVID-19 vaccinations or frequent testing for federal employees. This order also contained a requirement that employees of federal contractors working at federal facilities must show proof of vaccination or a recent negative COVID-19 test to enter the premises. Affected contractors are working to assess and communicate these requirements to their employees.

The executive order created a task force empowered to review, among other things, federal policies with regard to contractor vaccination requirements. When the initial federal contractor vaccination mandate was released, the task force advised contractors that it would consider expanding the requirement to employees who are not present at federal facilities.

The clear hint from this announcement is that eventually the government could tie federal contracts to a broader vaccine mandate for employees of such contractors. Affected employers should begin considering the potential impact of a broader mandate on their workforces and business, and they should create contingency plans for implementing any additional vaccination requirements.