President Obama’s “Fair Pay and Safe Workplaces” Executive Order (13673), issued in 2014, at last is going into effect. The Order requires federal contractors and subcontractors to report a three-year history of violations of fourteen different labor and employment laws, to the government as part of the procurement process. The government can deny a federal contract to a contractor with a sufficiently negative compliance record.
The first wave of reporting, for prime contractors, is due on October 25, 2016.
The Order, its implementing regulations, and the Department of Labor’s published “Guidance,” consisting of nearly 900 pages, contain a myriad of definitions and standards that must be distilled and followed. For large or decentralized companies, reporting presents particular challenges.