Wasting Away -- DOL Opines That Oil Waste Services Company Has a Retail or Service Concept

On August 31, 2020 the U.S. Department of Labor (DOL) published an official Opinion Letter regarding the new “retail concept” regulations expanding the reach of the overtime exemption of the Fair Labor Standards Act (“FLSA”) based on new rules it had promulgated on May 19, 2020. DOL found that a previously ineligible industry — oil field services/waste management — was now eligible for the Section 7(i) overtime exemption to the FLSA. Thus, DOL has lit the way for more enterprises to use his overtime exemption.

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Keeping Track of Time: DOL Issues "Reasonable Diligence" Guidance for Monitoring Teleworking Hours

The Department of Labor (“DOL”) recently issued guidance regarding an employer’s obligation under the FLSA to track the number of hours of compensable work performed by employees who are teleworking. Essentially, employers are required to exercise reasonable diligence in monitoring work hours without discouraging employees from reporting their legimate hours worked. Read on to learn our take on this new guidance.

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The Silly Season in Government Contracting Arrives Early—The Rush Is on to Issue Executive Orders, New Rules, and to Bring Judicial Challenges

The Trump Administration isn’t necessarily a lame duck, but it sure is acting like it by rushing employment law regulations and Executive Orders into place like this is their last chance. We have seen this show before, and it usually doesn’t end that well.

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Choosing NAICS Codes: In the Size of the Beholder

A Contracting Officer’s choice of what industry classification (aka NAICS code) applies to a contract can determine whether a business is or is not eligible to compete for a small business set aside contract. It all comes down to the size standards applicable to the chosen category. Read on to learn more about the implications of such classifications and whether you can do something about a bad choice.

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DIY No More: The End of Self-Certifying Woman-owned Small Businesses

The Small Business Adminstration (“SBA”) recently changed the process by which companies can obtain certification as Women-Owned Small Businesses (WOSB) or Economically Disadvantaged Small Businesses (EDWOSB). Self-certification no longer is an option. Here’s what companies need to know to obtain new certifications or to figure out if your current certification might be in jeopardy.

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Can I Please Have Some More, Sir -- Advancing Vacation Benefits Under the Service Contract Act

When new employees start work on a SCA covered contract, the employer faces a connundrum with respect to vacation bnefits. The employer can furnish the benefits immediately, and just pay benefits in excess of the SCA, resulting in payments above the minimum prevailing wage and impairing its right to a price adjustment the next option year. Or it can pay no vacation benefits, or just give leave without pay, and demoralize the new workers. But there is a third although relatively infrequently used course of action called an advanced or prepayment agreement or policy whereby the worker elects to receive the vacation benefit immediately on hiring, but the employer reserves the ability to get a credit for furnishing the benefit on the next anniversay date of employment.

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Left at the Altar: What to do if Key Personnel Proposed for a Service Contract Break their Commitments?

Many service contracts require that certain jobs, i.e., “key positions,” be held by highly qualified personnel dedicated to the project. So, what happens if that rock star project manager you spent months recruiting for a “key position” bails out on you in the middle of the competition to win the very contract the rock star was proposed to manage?

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In a Qui Tam Case Where It Is the Real Party in Interest, the Government Can Be Responsible for the Contractor's Legal Fees Under the Spearin Doctrine

The Government has several avenues to pursue damages when a contractor commits fraud, including bringing its own False Claims Act suit or joining a proxy qui tam lawsuit. But what happens when the Government’s mistake leads to a contractor’s damages? In a recent case, a contractor invoked the so-called Spearin doctrine to recover legal fees from an erroneous qui tam lawsuit.

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Avoiding Exemption Classification Mishaps When Confronting Covid-19 Financial Pressures and Salary Reductions

Employers facing the pressure of Covid-19 or different business slowdown, and considering a reduction of exempt employee pay and hours of work, may be relieved to know that a bona fide reduction of hours due to financial exigencies will not prevent an employee from still qualifying as exempt. if still paid over the miminum salary threshold.

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