Colleges and universities with U.S. government-sponsored research or other non-grant funding take note. On September 9, 2021, President Biden signed Executive Order 14042 to implement COVID safety protocols for Federal service contractors and subcontractors. Among other things, Executive Order 14042 requires that entities holding Federal contracts (or “contract-like instruments”), including colleges and universities, mandate vaccinations and other safety protocols for a wide swath of their employees. Unlike the forthcoming related OSHA rule, Executive Order 14042 does not permit employees to provide regular negative test results in lieu of proof of vaccination. This summary alert highlights a few of the issues that will be of particular importance to institutions of higher education.
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