As noted in our recent Government Contracts blog, government requirements for vaccination, masking and testing are in constant flux. On Sept. 9, 2021, President Joe Biden released a number of new vaccine mandates, one of which targets federal contractors, discussed in a Sept. 10 Holland & Knight Government Contracts alert. Landlords and lessors to the government are federal contractors, so these mandates will apply to all employees and subcontractors – to include janitorial and maintenance service providers – servicing federal leases to the GSA, the VA and all other government agencies.
While this requirement may not apply to higher-level ownership of Special Purpose Entities, landlords and property owners should continue to monitor this space as President Biden also has directed the U.S. Department of Labor's Occupational Safety and Health Administration (OSHA) to issue an Emergency Temporary Standard (ETS) implementing vaccination or testing requirements for all U.S. businesses with 100 or more employees. As such, even those higher-level ownership entities which are excluded from the Executive Orders' coverage should determine whether they may still have to comply with the ETS.
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