On Thursday, September 9, 2021 the Biden administration issued a plan and some Executive Orders relative to the pandemic, including an Order requiring COVID-19 vaccines for certain workers such as “federal contractors.” This Executive Order addresses the approach for federal contractors, and the plan itself directs the Occupancy Safety and Health Administration (OSHA) to initiate rulemaking for certain private employers. The timeline for federal employees and contractors to be fully vaccinated is only 75 days and given the waiting periods between shot one and shot two for some of the vaccine options, that is a rather short window. Since credit unions have been deemed “federal contractors” for some purposes such as under the Department of Labor’s (DOL) affirmative action plan rules, some CUs have been asking if this will apply to their operations.
Unfortunately, the full picture will not become clear until regulators start taking steps to implement the plan and Executive Order. However, here is some information that may help credit unions trying to assess how they may be impacted.
Executive Order and Federal Contractors
The Executive Order has a section on applicability of the mandate for federal contractors. The language focuses on those entities that contract with the federal government as opposed to being a federally insured entity.