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Executive Order 14042, issued on September 9, 2021, requires that certain federal contractors and subcontractors mandate vaccinations against COVID-19 for covered employees in addition to requiring compliance by covered employees and visitors with other COVID-19 safety protocols.

However, E.O. 14042 leaves several questions unanswered, including how agencies should implement the order and, in some cases, what types of contracts are covered.  Government agencies have begun to issue guidance in the form of class deviations, the substance of which we are providing as a side-by-side comparison.

Crowell & Moring LLP is tracking this emerging guidance, and is pleased to present this table, current as of the date on the table.