OMB Pauses Enforcement of Federal Contractor Vaccine Mandate In Light of Court Injunctions

Smith Anderson – On December 9, 2021, the Office of Management and Budget issued updated guidance to address the nationwide injunction that currently bars, on a preliminary basis, enforcement of the federal vaccine mandate. For federal contracts or contract-like instruments that already include a clause implementing the requirements of Executive Order 14042 (i.e., FAR 223-99), agencies are to notify the contractor that “[t]he Government will take no action to enforce the clause” where the place of performance identified in the contract is a U.S.