The Department of Labor has extended the public comment period for the U.S. Department of Labor’s proposed guidance (“DOL Guidance”) implementing President Obama’s “Fair Pay and Safe Workplaces” Executive Order (E.O. 13673).  The Department of Defense has done the same with respect to the Federal Acquisition Regulatory (“FAR”) Council  proposed regulations (“FAR Proposed Rule”) implementing the Executive Order.  The public comment period now closes August 11, 2015.

The extension of the deadline allows employers more time to evaluate the effect of the new obligations and potential unintended consequences.  Mickey Silberman was quoted this morning in the Wall Street Journal’s Risk and Compliance Journal speaking about the reality of companies taking the time

to assess the value of the government contracts they have and weighing that against the greatly increased cost of doing business with the federal government.

In preparation for the new regulations, Mickey suggested companies:

need to budget for higher costs, should identify a person or team to handle coordinating the collecting of information from its various departments and subcontractors, and should make sure its lawyers understand the ramifications of setting cases versus the larger-picture risk of adding a violation to the total.

With today’s extension, there’s still plenty of time to comment on the impact of these proposed rules and guidance – let your voice be heard.