Federal contractors know that keeping up with developments in employment laws, regulations, and best practices is a job in itself, and that looks to again be the case heading into 2022. The Office of Federal Contractor Compliance Programs (OFCCP) has long required contractors to create Affirmative Action Plans (AAP), but to date the only tool the OFCCP had to verify that federal contractors were creating, and following, AAPs was subjecting contractors to random audits.
This looks to change dramatically in 2022, once the OFCCP opens its “AAP-VI” online reporting system. Although the date the new AAP-VI reporting system will go online is uncertain, what is almost certain is that all federal contractors will likely have to submit yearly AAPs to the system. Historically, when federal contractors are subjected to an audit, not having a written AAP on file is among the most common violations. However, that is likely to change under an AAP-VI reporting system that places reporting burden on every federal contractor rather than the unlucky few that are audited.
Also of consequence to federal contractors is the implementation date of Executive Order 14026, which raises the minimum wage for all federal contractor workers to $15 per hour. Beginning January 30, 2022, all new contracts, renewals of contracts, and extensions of existing contracts must comply with the $15 minimum wage requirement. Federal contractors should note that although the scope of who qualifies as a worker who must receive the $15 per hour wage is very broad, it is not absolute.
There are a number of nuanced exceptions that may exempt either a worker or the type of work the worker is performing from being entitled to the $15 minimum wage. Federal contractors will have to take adequate steps to ensure that they are aware of the new federal contractor minimum wage and which of their employees are entitled to receive it.
Source: National Law Review
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