Juneteenth is here... tomorrow!

Most federal workers will have tomorrow off in observance of the newly declared Juneteenth federal holiday. We previously posted a blog about the National Day of Mourning observing the death for President George H.W. Bush. While tomorrow’s celebration of freedom is so different from a day of mourning, they share the trait of being unexpected federal holidays that have an impact on federal contractors. Read on to learn more about the issues and options available when faced with an unexpected federal holiday.

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All Animals Are Created Equal: Application of the Service Contract Act (“SCA”) to State and Local Governments and Wage Determination Loopholes

The Service Contract Act (“SCA”) can apply to state and local governments, including public universities performing research and other government contracts. But when it comes to those public entities, they may have a loophole to get a special wage determinaton.

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Must Cash Payments in Lieu of SCA Mandated Fringe Benefits be included in FLSA Overtime Rates?

The Service Contract Act requires federal service contractors to provide certain fringe benefits to their employees. Some contractors pay cash in lieu of providing the benefits. Since the Fair Labor Standards Act requires payment of overtime based on a regular rate of pay, there’s a question as to whether cash-in-lieu payments must be added to wages to come up with the regular rate of pay. Read on to see how the Department of Labor and several courts reach different conclusions and how contractors should weigh their options.

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You Can’t Always Get What You Want:  Under Service Contract Act, Emergency Contract Was Subject to Predecessor’s CBA

The award of an emergency follow-on contract to a new successor contractor doesn’t change the operation of the Service Contract Act (“SCA”) Section 4(c) succcessor contractor rule. The follow-on contract is still subject to the wages and fringe benefits set forth in the collective bargaining agreement (“CBA”) entered into by the predecessor contractor.

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DOL Is Putting Service Contract Act Fringe Benefit Plan Administrative Costs Under the Microscope 

The SCA bars contractors from allocating their own plan administrative expenses towards compliance with the prevailing H&W fringe benefit However, this doesn’t bar an employer from claiming a credit for the expenses borne by the benefit plan. This dichotmy sometimes produces disputes and misunderstandings. Lately, DOL has been eying a more aggressive stance on administrative expenses.

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Want to Stop Shortchanging Service Contract Employees? Fix the System

Increasing service contract employee wages is laudable. Likewise, there should be robust and fair enforcement to ensure adherence to applicable laws, wage rates, and benefits. However, true reform must also include sound acquisition policy that incentivizes competitive compensation and benefits for employees and simplifies the process of finding the correct wage rates under the Service Contract Act.

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