Continuing to pursue his pay equity agenda, President Obama took the steering wheel by issuing two Executive Orders and a game-changing Presidential Memo in February and April.  Each of these actions requires the Department of Labor (DOL) to issue proposed regulations to implement the actions and flesh-out the many details not addressed in the Executive Orders and Memo.  The devil, as they say, is in the details and each of these proposed regulations is subject to public notice and comment prior to their finalization.  This means your comments.

  • Presidential Memo:  directs DOL to propose regulations requiring contractors to submit to OFCCP summary pay, race and gender data on their employees
    • Proposed regulations due early-August 2014
    • On par with the new veteran and disability regulations, these proposed regulations will fundamentally change compliance for federal contractors.  Presently, we know very few of the details of this proposal; thus, the proposed regulations will be our (your) first opportunity to be heard regarding regulations which may impact federal contractors for years to come.


  • Executive Order 13665:  no retaliation against applicants or employees for inquiring about, discussing or disclosing pay
    • Proposed regulations due mid-September 2014


  • Executive Order 13658:  minimum wage for federal contractor employees to $10.10/hour
    • Proposed regulations due October 1, 2014
    • Open Questions: how will OFCCP define “contract” and “federal contractor,” and are all contractor employees covered or only those working on the federal contract.

Make sure you keep dates on your radar and consider submitting comments to the proposed regulations.   Continue to check back here during these timeframes as we will continue to provide important updates and insights on these proposals.