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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.


Insights

Client Alert | 2 min read | 12.19.25

GAO Cautions Agencies—Over-Redact at Your Own Peril

Bid protest practitioners in recent years have witnessed agencies’ increasing efforts to limit the production of documents and information in response to Government Accountability Office (GAO) bid protests—often will little pushback from GAO. This practice has underscored the notable difference in the scope of bid protest records before GAO versus the Court of Federal Claims. However, in Tiger Natural Gas, Inc., B-423744, Dec. 10, 2025, 2025 CPD ¶ __, GAO made clear that there are limits to the scope of redactions, and GAO will sustain a protest where there is insufficient evidence that the agency’s actions were reasonable....