COVID Vaccine Mandate: What does Compliance Look Like?

Many federal contractors are being asked to accept contract modifications to implement President Biden’s vaccine mandate. So, what will compliance look like? For now, things are a bit vague; however, we hope the roll-out of this mandate will be reasonable. Contractors should be allowed some flexibility if they’re making good-faith efforts to cajole their workforces into being fully vaccinated.

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One for Me; and One for Me: Getting Paid for SCA Vacation Benefit Increases in Option Year

Offerors are entitled to a SCA price adjustment for increased costs incurred for vacation pay benefits during a contract renewal option period. Savvy offerors will exclude those vacation benefit costs for their bid costs in order to get a compeittive advantage. But this doesn’t work for existing employees or those hired from the predecessor contractor, who are entitled to a grant of vacation benefits in the base term of the contract.

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Davis-Bacon Classification Decision Was Not Arbitrable, Tenth Cir. Holds

The Tenth Circuit holds that the Union in this case cannot compel the Contractor to arbitrate Davis-Bacon job classifications. However, the court did not hold that Davis-Bacon job classifications are not arbitrable. This article was written by our very own Kirby Rousseau for The Government Contractor publication.

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COVID Vaccine Mandate for Federal Contractors: A Work in Progress

The evolving COVID-19 vaccine mandates for federal employees and contractor employees are a work in progress. New Executive Orders that will require near universal vaccination of employees are replacing the vaccine-or-test mandate issued mere weeks ago. Read on for more about the new requirements and the confusion that may ensue in the meantime.

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Catch-22: No Contractor Price Adjustments for State Minimum Wage Increases

When bidding on and pricing US government extended term fixed price contracts, contractors need to price in the possibility that state minimum wages will exceed the SCA or DBA wage levels, and require an escalation be paid, but the contracting agency will not adjust the contract price for that occurrence.

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Getting Back on the Horse - District of Columbia Plaintiffs May Have Found a Way to Privately Enforce Prevailing Wages

The District of Columbia is allowing workers to bring a prevailing wage claim under the guise of a municipal statute, thereby eroding the rule that only DOL enforces the federal prevailing wage laws and there is no private cause of action.

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Vaccine or Test: Do Contractors Have to Foot the Bill to Test Employees Who Refuse Vaccines?

UPDATE: President Biden is expected to announce executive orders that will mandate universal vaccination for federal workers and contractor employees with no testing option. We will post an update when the expected orders are issued. Federal contractor employees who work on Government sites must comply with President Biden’s vaccine or test policy. Must contractors pay employees for their time to get tested if they refuse to get a vaccine? Must contractors foot the bill for the tests? So far, these questions are going unanswered.

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A Modest Proposal for Prepayment of SCA Vacation Benefits

Just what you have been waiting for all your life — here is a short policy providing for the pre-payment or advanced payment of SCA vacation benefits to new workers who otherwise would have no paid leave, particularly in their first year of employment. Please note, it remains unclear whether DOL will approve of the use of such a policy, but then you are no worse off than before.

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DOL Issues Proposed Rule on Contractor Minimum Wages: What’s New?

On July 21, the Department of Labor (“DOL”) published proposed regulations that implement President Biden’s Executive Order establishing a $15 an hour minimum wage for workers who perform on or in connection with federal contracts. While this is a new rule, it’s nearly identical to the existing federal contractor minimum wage requirements. Thus, what was clear before is still clear. What wasn’t, isn’t.

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Don’t Be a Bag Holder: Be Proactive On Subcontractor Prevailing Wage Compliance

Here is an unofficial “form”, with some minor edits and adjustments made by us, which requires subcontractors to acknowlege their obligations with repect to the prevailing wage laws. It is no panacea or substitute to good flow down of subconract terms, but in one page it does an effective job of emphasizing the duties being imposed on the subcontractor, and thus can help avoid misunderstandings or minimize inadvertent errors.

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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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