Executive Order 14042 Agency Class Deviation Guidance, A Side-by-Side Comparison
Client Alert | 1 min read | 10.08.21
Executive Order 14042, issued on September 9, 2021, requires that certain federal contractors and subcontractors mandate vaccinations against COVID-19 for covered employees in addition to requiring compliance by covered employees and visitors with other COVID-19 safety protocols.
However, E.O. 14042 leaves several questions unanswered, including how agencies should implement the order and, in some cases, what types of contracts are covered. Government agencies have begun to issue guidance in the form of class deviations, the substance of which we are providing as a side-by-side comparison.
Crowell & Moring LLP is tracking this emerging guidance, and is pleased to present this table, current as of the date on the table.
Contacts
Insights
Client Alert | 14 min read | 03.13.26
AI for Government: 7 Days for Contractor Comments on GSA Proposed Contract Clause for AI Systems
On March 6, 2026, the General Services Administration (GSA) issued a significant proposed contract clause, GSAR 552.239-7001, Basic Safeguarding of Artificial Intelligence Systems (“Clause”), for inclusion in GSA Schedule solicitations and contracts for AI capabilities. The proposed clause would impose substantial new requirements related to AI sources, intellectual property rights, data use, change management, and performance standards. The Clause would also take precedence over any other contract terms (including commercial licensing terms) related to AI, including a Seller’s terms of sale and service to which the Government had previously agreed. GSA requests comments by March 20, 2026.
Client Alert | 3 min read | 03.12.26
DOJ Releases First-Ever Department-Wide Corporate Enforcement and Voluntary Self-Disclosure Policy
Client Alert | 3 min read | 03.12.26
