COVID-19 VACCINATION GUIDANCE
Team Sabree -
As you are aware, the President signed Executive Order 14042, Ensuring Adequate Covid Safety Protocols for Federal Contractors, which requires covered contractors to comply with all the guidance published by the Safer Federal Workforce Task Force.
Our primes have provided information related to our Customer’s Office of the Procurement Executive (OPE) Notice #30, and advised that they would provide additional information as it becomes released. On October 15, our customer issued OPE Notice #31 (“Notice”) which provides additional guidance and they are providing this communication to our us accordingly.
The Notice states the following:
A. Our customer will start modifying all their contracts for services, including construction of any dollar value to:
Incorporate FAR 52.223-99 Ensuring Adequate COVID Safety Protocols for Federal Contractors (OCT 2021)
Incorporate Clause x52.223-99 Addendum to FAR 52.223-99 (OCT 2021); and
Incorporate and/or update, if applicable, CLAUSE x52.204-780 Mandatory Coronavirus Vaccine for Contractors Traveling Outside the United States (OCT 2021)
NOTE: Primes have not yet received a copy of x52.223-99 or x52.204-780 but they are forthcoming and will be flowed down to all subcontractors after receipt.
B. All contractor personnel are required to be fully vaccinated, except in limited circumstances where legally entitled to an accommodation, not later than 8 December 2021. This includes contractor personnel that are “covered contractor employees”. Contractors are strongly encouraged to pursue achieving full compliance by 22 November 2021, as it would represent a valued action-based demonstration of your commitment and partnership.
C. Contractor/subcontractor personnel performing work at a federally controlled workplace within the United States or its outlying areas must be fully vaccinated without exception. Fully vaccinated is defined as 14 days after the second/final dose of a vaccine approved or authorized by the US Food and Drug Administration. Adjudication of all requests (medical or religious) for reasonable accommodations for industrial contractor personnel are the responsibility of Sabree and these requests will not not be submitted to our primes or the Government for review or approval.
D. Contractor/subcontractor personnel performing working remotely (from home) within the United States or its outlying areas must be fully vaccinated without exception. Fully vaccinated is defined as 14 days after the second/final dose of a vaccine approved or authorized by the US Food and Drug Administration. Adjudication of all requests (medical or religious) for reasonable accommodations for industrial contractor personnel are the responsibility of Sabree and these requests will not not be submitted to our primes or the Government for review or approval.
E. Contractors who identified covered employees to whom they are legally obligated to provide accommodations may propose for the prime and the Customer’s consideration, alternate methods of performance including, but not limited to, substitution of personnel and/or a change in place of performance.
Subcontractors must comply with these requirements and all their contractual obligations. Once the contract modification is received, all requests for alternate methods of performance will need to be authorized by the prime and its customer, and as such must provide for efficient satisfaction of contractual obligations. Please note that there is a possibility that our contract modification will not allow a change in the “place of performance” and if that is the case, a substitution of personnel will be required. If the prime contract modification allows a change in “place of performance” we believe there will be very limited approvals as almost all of our work is conducted at customer facilities on customer systems. Primes will not be able to provide seating with the appropriate system access as a part of any alternate method of performance.
In addition, a vaccination status will now be required for all new resources joining the program. S3 will be requested to confirm our resource as vaccinated, un-vaccinated or not willing to attest as part of the onboarding process for all new resources being proposed to the team.
As guidance continues to flow from our prime partners, I will continue to keep you updated.
Sabree appreciates your continued cooperation!