Compliance

FAR Council, CAAC, and DoD Release COVID-19 Guidance

The FAR Council, the Department of Defense (“DoD”), and the Civilian Agency Acquisition Council (“CAAC”) have released guidance for federal government contractors on COVID-19 safeguards required by President Biden’s September 9, 2021, Executive Order 14042 (the “Order”) and the Safer Federal Workforce Task Force’s September 24, 2021, Guidance, COVID-19 Workplace Safety: Guidance for Federal...
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Civilian Agency Acquisition Council (“CAAC”) Memorandum: Class Deviation Regarding Executive Order 14042 Ensuring Adequate COVID Safety Protocols for Federal Contractors

On September 30, 2021, the Civilian Agency Acquisition Council (“CAAC”) released a memorandum authorizing all civilian United States government agencies to issue a class deviation to implement Executive Order 14042, “Ensuring Adequate COVID Safety Protocols for Federal Contractors.” Attached to the CAAC memo is a FAR Deviation Clause (the “Clause”) that CAAC states “is...
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Federal Vaccine Mandate Requires Contractor Employees To Be Fully Vaccinated By December 8, 2021

Posted on October 6, 2021
Federal contractor employees—with some limited exceptions—must be vaccinated by December 8, 2021 per guidance released by the Biden administration on Friday.1 The mandate applies to part- and full-time employees of contractors (or subcontractors) who are working either directly on or “in connection with” a contract, including indirect support of a contract like “human resources, billing,...
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New Vaccination Requirements Imposed On Government Contractors and Other Employers and Employees

On Thursday, September 9, 2021, President Biden announced new federal COVID-19 vaccination requirements, outlined below, which will be incumbent on federal government contractors and their employees, federal branch employees, as well as private sector employers with over 100 employees. Federal Government Contractors President Biden signed an Executive Order on Ensuring Adequate COVID Safety Protocols for...
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Beyond Whack-A-Mole: Effective Ethics & Compliance Programs For Small Contractors

Posted on February 17, 2021
Small government contractors are in an unenviable position when it comes to developing effective ethics and compliance programs. On the one hand, profit margins are low, competition is fierce, and financial and personnel resources are scarce -- particularly for tasks that do not contribute immediately to the bottom line. On the other hand, government...
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Records Retention Requirements for Federal Contractors

Posted on February 16, 2021
Federal contractors must know the requirements for maintaining records pertaining to work performed on federal contracts. Unfortunately, there’s not one definitive answer on how long a record should be kept. Often, the first step for determining how long a record must be kept is identifying what type of records your organization creates and maintains...
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