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.

Photo of Anne Perry Anne Perry

Anne Perry is a partner and former Practice Leader of the Governmental Practice in the firm’s Washington, D.C. office.

Photo of Denise Giraudo Denise Giraudo

Denise Giraudo is a partner in the Labor and Employment Practice Group in the firm’s Washington, D.C. office.

Photo of Emily Theriault Emily Theriault

Emily Theriault is an associate in the Governmental Practice in the firm’s Washington, D.C. office.

Photo of Ryan Roberts Ryan Roberts

Ryan Roberts is a partner in the Governmental Practice in the firm’s Washington, D.C. office. He is also a member of the firm’s Aerospace and Defense and Retail Industry Teams.

Photo of Jonathan Aronie Jonathan Aronie

Jonathan Aronie is the Leader of the firm’s Governmental Practice Group and is a former Managing Partner of the Washington, D.C. office. Jonathan also is a founding member of the firm’s Organizational Integrity Group, a cross-disciplinary team of litigators, regulatory specialists, federal monitors…

Jonathan Aronie is the Leader of the firm’s Governmental Practice Group and is a former Managing Partner of the Washington, D.C. office. Jonathan also is a founding member of the firm’s Organizational Integrity Group, a cross-disciplinary team of litigators, regulatory specialists, federal monitors, and ex-prosecutors with extensive experience helping organizations prevent and defend against challenges to their organizational integrity.