FEDERAL CONTRACTOR ALERT: Paid Leave, Pay Transparency, Equal Pay Report, Compliance Tools

Document created by 1032141 on Sep 4, 2015Last modified by 1002028 on Sep 13, 2015
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kaleigh.jpgOver the last few weeks, the Office of Federal Contracts Compliance Programs (OFCCP) has been very busy. Below I highlight four areas that all Federal Contractors and Subcontractors should become familiar.  Please reach out to our Advice and Resolution team or to me directly Kaleigh Ferraro should you have any questions. 

 

PAID LEAVE

On September 7th President Obama issued an Executive Order requiring federal contractors (and subcontractors, including lower-tier subcontracts) to offer their employees up to 7 days of paid sick leave per year.  Under the EO, employees of federal contractors and subcontractors will earn a minimum of one hour of paid sick leave for every 30 hours worked. A contractor may not limit annual paid sick leave accrual at less than 56 hours; contractors are free to offer more generous leave amounts at their discretion, however. Workers may use the paid sick leave to care for themselves or a family member, or for absences resulting from domestic violence, sexual assault, or stalking. The EO directs the Secretary of Labor to issue regulations enforcing the EO by September 30, 2016. 

 

Obama is also once again asking Congress to pass the Healthy Families Act, which would require all employers with 15 or more employees to offer up to 7 paid sick days per year, or to pass other federal legislation “guaranteeing every working American paid family and medical leave to care for a new child, a seriously ill family member, or their own serious illness.” And he will urge other states and municipalities to follow the lead of Boston, and Massachusetts, and other state and local governments that have similarly expanded paid leave for private employees.

 

PAY TRANSPARENCY

The Office of Federal Contract Compliance Programs (OFCCP) is publishing a Final Rule that promotes pay transparency by prohibiting federal contractors and subcontractors from discharging, or otherwise discriminating against their employees or job applicants for discussing, disclosing, or inquiring about compensation. The Final Rule takes effect on January 11, 2016, and implements Executive Order 13665, signed by President Obama on April 8, 2014. 

 

EQUAL PAY REPORT

On August 6, 2014, the OFCCP announced a Notice of Proposed Rulemaking requiring covered federal contractors and subcontractors with more than 100 employees to submit an annual Equal Pay Report on employee compensation. Last we hear, the final rule was due out in November of 2015.  More to come as we hear more.

 

OFCCP COMPLIANCE TOOLS

The OFCCP recently released several compliance tools to provide tools and assistance for compliance with the revised regulations for protected veterans and individuals with disabilities.

 

  • Infographic for veteran status: Assists veterans in determining if they are a protected veteran under the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA)

 

  • Section 503 Checklist: Outlines the requirements of Section 503 of the Rehabilitation Act.  Federal contractors/subcontractors may find this checklist helpful in determining their compliance with the revised regulations

 

 

  • OFCCP Customer Experience Survey:  The OFCCP also posted on their website information about a customer experience survey they deployed. This survey sent electronically to contractors/subcontractors who have been audited in the last four years is intended to anonymously collect information about contractors’ experience during audits.

 

Just in: The filing period for EEO-1 has been extended and is now due by October 30, 2015.  The VETS-4212 report is also open and as of this moment is due by September 30, 2015!!

 

If you have questions regarding these tools or affirmative action in general, please contact Kaleigh Ferraro, Manager of Affirmative Action Services, at kaleigh.ferraro@captial.org or 919.713.5241.   We also invite you to sign up for our free one hour webinar AAP: Checking in on Current Happenings on September 15, 2015 (www.capital.org/aap to register).

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