Christopher Wilkinson was quoted in the Bloomberg Law article, "Contractor Workers Must Get Vaccine by Dec. 8, White House Says," regarding the White House guidance from the Safer Federal Workforce Task Force.

Biden’s order doesn’t apply to businesses with contracts valued below the “simplified acquisition threshold,” which is generally set at $250,000, or subcontractors that provide only products.

However, the guidance doesn’t “directly address the avalanche of coverage questions my clients have been asking,” said Christopher Wilkinson, a former U.S. Labor Department attorney who now counsels employers at Perkins Coie LLP in Washington.

“These threshold questions will continue to muddy the path forward for many companies,” he said.

Smith raised similar concerns, saying the guidance encourages businesses to apply the requirements to contracts excluded from coverage.

“So for contracts such as those for products, or that are under the simplified acquisition threshold, it’s unclear which (if any) will incorporate the EO’s requirements—and thus whether employees performing on or in connection with those contracts will be subject to vaccination requirements,” he said. “That adds uncertainty to decisions on where to focus attention in ensuring compliance with the vaccination and other requirements.”