A Look Behind the Curtain: Recent Bid Protest Decision Offers Insight into Corrective Actions

Conventional wisdom holds that bid protests are an uphill battle. It can be tough to win them. And sometimes when you win, you still lose because the contract’s still awarded to your competitor. A recent bid protest decision illustrates how a successful protest prompted the agency to appoint a new evaluation team that changed the outcome.

Read More
You're Not Too Big Unless You're Asked if You're Too Big: Recertification of Small Business Status

Contractors who are experienced in the world of multiple award contracts likely are familiar with how the small business regulations operate under those contract vehicles. However, there are some wrinkles. Small businesses that are considering whether to dive into this world should learn more about the maze of small business regulations so they can anticipate the potential pitfalls that could come with success.

Read More
Facing a Size Protest? SBA Might Want Your Tax Returns

Yesterday’s tax filing deadline brought to mind a recent Small Business Administration decision in which a contractor lost out because it didn’t supply its tax returns. If SBA knocks on your door because a protest has been filed, don’t leave things to chance. Respond in a timely and complete manner—you want to make it easy for the SBA to see things your way.

Read More
Back to Basics: SCA Price Adjustments on Cost Reimbursement and Hybrid Contracts

Service Contract Act (“SCA“) covered fixed priced contracts generally have one of two FAR clauses for price adjustments — either FAR 52.222-43 or -44. But there are different price adjustment clauses and provisions for cost reimbursement contracts. Where the SCA provisions and the standard cost reimbursement clauses overlap is in hybrid contracting, involving both fixed price and cost reimbursement CLINS. In those circumstances the overlapping price adjustment issues can be murky.

Read More
Don’t Look Now -- the Government Contractor ETF is Gone.

It looks likes the sponsor of the government contractor FEDX ETF I like to blog periodically about has pulled the plug. As far as I can tell the ETF is no more. I speculate it had insufficient assets to be profitable for its sponsor. What this means about Government contracting I can’t discern, except to say that as an investment idea it didn’t catch on.

Read More
What the. . .? Another Arrest for Failure to Respond to DOL Subpoena

DOL recently announced that US Marshals arrested a New York restaurateur for failure to respond to a subpoena as part of a Fair Labor Standards Act investigation. This is the second such arrest in the last few months. As I said in my blog about the first arrest - things simply go better when employers take DOL investigations seriously.

Read More
Arbitrability of Service Contract Act or Davis-Bacon Act Job Classification Disputes – Don’t Go There!

Some disputes are not meant to be litigated in court or arbitrated. One example is job classification disputes under the Service Contract Act (“SCA”) or the Davis-Bacon Act (“ DBA”). Such disputes are committed to the exclusive jurisdiction of the U.S. Department of Labor. Only DOL is supposed to decide them and then provide for administrative appeals. Don’t let your union drag you into an arbitration of job classification disputes on service and construction US government contracts.

Read More
Check the Water Before You Dive In: GAO Rejects Protest that Government Should Have Clarified Application of Service Contract Act

Contractors are on their own when it comes to determining what wages they must pay under a contract covered by the Service Contract Act. That’s exactly what the Government Accountability Office held when it denied the protest of a prospective contractor that sought a ruling about when under a diving services contract it should pay prevailing wages to its divers.

Read More
The Sky is Falling? Competing Proposals to Prohibit Noncompete Agreements

Noncompete agreements are under attack by recent proposals coming from the Biden Administration as well as a bipartisan group of Senators. Such clauses are standard fare for employment agreements, particularly for senior executives. However, in this world of remote work and a patchwork of state laws, a national rule might not be so bad after all. So, fear not, the sky actually might not fall if one of these proposals comes to pass.

Read More
Help Is on the Way – Polish Your Resume to Become a Procuring Agency Labor Advisor

Just out — a White House memorandum directing all federal contracting agencies to hire labor advisors to help coordinate with DOL and comply with the laws regarding labor and employment which pertain to federal procurements. This includes especially the Service Contract Act and the Davis-Bacon Act, but also many other labor requirements and Executive Orders.

Read More