With President Trump’s second administration set to begin on January 20, 2025, federal contractors and subcontractors are anxiously awaiting what he might do with respect to the Office of Federal Contract Compliance Programs (“OFCCP”) and the employment obligations imposed on federal government contractors. While the Trump transition team has not
federal contractors
FAR Council Withdraws Proposed Contractor Pay Inquiry and Transparency Rule
Effective as of January 8, 2025, the FAR Council has withdrawn a proposed rule that would have limited federal contractors from seeking and considering information about job applicants’ compensation history and required contractors to disclose salary ranges in job postings.
The announcement states that “in light of the limited time…
United States Government Accountability Office Finds Federal Contracting Rules do not Prohibit Labor Harmony Agreement Requirements
In a decision issued on September 16, 2024, the United States Government Accountability Office (“GAO”) ruled that federal contracting rules do not prohibit government agencies from requiring contractors to enter into labor harmony agreements.
In 2022, Maximus Federal Services, Inc. (“Maximus”), won a contract with the Department of Health and…
OFCCP Issues Directive Updating Expedited Conciliation Procedures
On July 26, 2024, OFCCP published Directive 2024-01: Expedited Conciliation Procedures (the “Directive”). The Directive is intended to “outline updated procedures for an expedited conciliation option, giving contractors and the agency flexibility in the resolution of violations.”
Background
Directive 2024-01 rescinds and replaces DIR 2019-02, Early Resolution Procedures, which established…
FAR Council Proposes Rule Requiring Contractors to Identify Subcontractors and Report Subcontractors’ Executive Compensation Information
On May 24, 2024, the Federal Acquisition Regulation (“FAR”) Council published a Notice and request for comments for 9000-0177, Reporting Executive Compensation and First-tier Subcontract Awards.
If approved, the new FAR will require contractors to: (1) publicly report certain information on their first tier subcontractors; and (2) report compensation information…
White House Issues First Artificial Intelligence Executive Order: AI Guidance for Federal Contractors Forthcoming
On October 30, 2023, President Biden issued an “Executive Order on the Safe, Secure, and Trustworthy Development and Use of Artificial Intelligence” (the “EO”), the first executive order directly addressing artificial intelligence.
Of particular interest to federal government contractors, the EO provides that within 365 days of publication…
Contractors: VETS-4212 Filing Window Now Open Until September 30, 2023
Federal contractors and subcontractors meeting the VEVRAA eligibility threshold of having 50 or more employees and at least one federal contract totaling $150,000 or more (“Covered Contractors”) must annually file a VETS-4212 Report. The VETS-4212 filing period is now open, and contractors have until September 30, 2023 to submit their…
DOL Issues Proposed Rule on Raising Minimum Wage to $15 per Hour for Federal Contractor Employees
Quick Hit
On July 21, 2021, the Department of Labor (“DOL”) announced a proposed rule (the “Proposed Rule”) to implement President Biden’s Executive Order (the “Order”) requiring an increase of the minimum wage for certain employees of covered federal contractors and subcontractors to $15.00 per hour – except for tipped…
BREAKING: The Government Shutdown Is Officially Here – What Does It Mean For Federal Contractors?
As of midnight on December 21, 2018, portions of the government have been shut down until Congress is able to pass a spending bill. Due to ongoing political fights surrounding the border wall, it remains unclear when the government will be fully operational again. In addition to the 400,000 government…

OFCCP Rescinds Active Case Enforcement Procedures
Quick Hit: Office of Federal Contractor Compliance Programs (“OFCCP”) has issued Directive 2019-01 (the “Directive”), which rescinds Directive 2011-01 which established OFCCP’s now-defunct Active Case Enforcement or “ACE” policy. Through ACE, OFCCP conducted fewer but more intensive compliance evaluations of government contractors. In issuing the Directive, OFCCP is formally ending ACE, while adopting an approach it contends keeps the better components of ACE while allowing OFCCP to conduct more compliance evaluations in a more efficient manner.