Posts in Government Contracts
When Is a Federal or State Specified Fringe Benefit Unallowable Under the Prevailing Wage Laws as a Credit Towards Compliance?

Sometimes the wage and hour regulations cannot be taken literally. Instead, you need to figure out the regulatory intent. For example, the SCA and DBA regulations bar the employer from claiming a credit for paying social security, worker’s comp and unemployment premiums. These tax like payments are not fringe benefits. But other federal and state mandated benefit plans like Obamacare, Romneycare in Massachusetts, holidays, and leave are fringe benefits and can be credited towards compliance.

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Where oh Where? Choosing the Correct Forum for Government Contracts Disputes

If a government contractor has a bone to pick, figuring out who to complain to can feel a lot like a customer service phone tree. If you press three instead of one, you can find yourself being transferred to another department after hours of being on hold. Or you can get completely different answers depending on who you speak to.

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Government Contractors: Help! Inflation's Killing Us--Government: We're Here to Help (or not)

The Director of Defense Pricing and Contracting recently issued a memo to guide contracting officers in response to the impacts of inflation on federal contracts. Read on to find out how there’s some hope for future contracts, but little relief for contractors who hold existing fixed-price contracts.

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State Fringe Benefit Requirements and the SCA and DBA Price Adjustment Clauses

Careful drafting of CBAs, particularly on service contracts, should include some attention to language expressly making any state mandated fringe benefits into a CBA contractual requirement. At least that would be prudent for a contractor looking to get a price adjustment for state mandated benefits.

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Court Holds Challenge to SCA Coverage of Cooperative Agreement Not Ripe for Appeal Due to Lack of Final Agency Action 

A U.S. District Court judge holds that a contractor had not received final agency action to allow an Administrative Procedure Act suit. Thus a challenge to DOL’s determination that the Service Contract Act applies to cooperative agreements is not ripe for appeal.

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There But for the Grace… Government Contracts Rules Lay Traps Aplenty

From time to time, I see a government contracts case that sends chills down my spine. A recent decision painfully reminds me of how the law governing our unique parcel in the vast lands of the legal world is rife with hard-to-see pools of quicksand that can trap even the most sophisticated contractors.

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Biden Executive Order Mandates Project Labor Agreements for Federal Construction Projects

President Biden issued an Executive Order on February 4, 2022 that will require contractors to enter into project labor agreements for large scale federal construction projects. Although PLAs have been “encouraged” for some time, this order will transform this preference into an absolute requirement.

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Annualization or Effective Annual Rate of Fringe Benefits Under the Davis-Bacon Act

DOL wants to annualize fringe benefit contributions, especially pension monies, to get contractors to pay Davis-Bacon Act fringe benefits even for non-Davis-Bacon Act work. This is variously called the annualization rule or the effective annual rate calculation. But some courts have refused to enforce the DOL annualization requirment.

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DOL: We’re Hiring!

The Department of Labor announced yesterday the Wage and Hour Division plans to hire 100 investigators this year. For sure, they’ll be earnest and energized. That’s why a solid grounding in the wage and hour laws affecting the government contractor community will be a powerful tool to ensure you get a fair shake.

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