Executive Order 14042 Survival Guide

Sheppard Mullin Richter & Hampton LLP

On September 9, 2021, the President issued Executive Order 14042, which applies new rules – including vaccination mandates – to Federal contractors and subcontractors. EO 14042 does not include a weekly testing option and is therefore a true vaccination mandate. The rule defines “Federal contractor” very broadly. As a result, the rule likely covers most companies doing business with the Federal Government, including employees of those businesses even if those employees are working from home (e.g., HR, legal, and billing employees who may not be on site). The rule also covers subcontractors at all tiers, including certain vendors. Sheppard Mullin’s Construction practice group diligently has been working in this area since the announcement of the Executive Order and release of related Task Force Guidance, and Sheppard Mullin’s Government Contracts group has developed an Executive Order 14042 Survival Guide that answers many of the questions related both to the EO and Guidance. Keep an eye out for updates to the Survival Guide as we continue monitoring the roll out of the new rule.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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