Over the past few weeks, landlords leasing space to the General
Services Administration (GSA) have begun to receive notices of
requirements that all personnel operating in GSA space certify as
to whether or not they have been fully vaccinated. GSA is also
requiring individuals maintain copies of the certification on their
person when in GSA-leased spaces.
At the same time, the U.S. Department of Veterans Affairs (VA),
relying upon its independent statutory authority, has implemented
new rules mandating all personnel in its medical facilities –
to include community-based outpatient centers (CBOCs) – be
vaccinated or obtain a legitimate religious or medical
exemption.
Landlords and service providers should monitor this issue
closely in the coming months. The requirements and deadlines are
changing week to week – and sometimes day to day – in
response to changing circumstances and guidance from the Biden
Administration. Below is a current snapshot of both the GSA
