The Department of Labor has extended the public comment period for the U.S. Department of Labor’s proposed guidance (“DOL Guidance”) implementing President Obama’s “Fair Pay and Safe Workplaces” Executive Order (E.O. 13673).  The Department of Defense has done the same with respect to the Federal Acquisition Regulatory (“FAR”) Council  proposed regulations (“FAR Proposed Rule”) implementing the Executive Order.  The public comment period now closes August 11, 2015.

The extension of the deadline allows employers more time to evaluate the effect of the new obligations and potential unintended consequences.  Mickey Silberman was quoted this morning in the Wall Street Journal’s Risk and Compliance Journal speaking about the reality of companies taking the time

to assess the value of the government contracts they have and weighing that against the greatly increased cost of doing business with the federal government.

In preparation for the new regulations, Mickey suggested companies:

need to budget for higher costs, should identify a person or team to handle coordinating the collecting of information from its various departments and subcontractors, and should make sure its lawyers understand the ramifications of setting cases versus the larger-picture risk of adding a violation to the total.

With today’s extension, there’s still plenty of time to comment on the impact of these proposed rules and guidance – let your voice be heard.

 

Print:
Email this postTweet this postLike this postShare this post on LinkedIn
Photo of Laura A. Mitchell Laura A. Mitchell

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with…

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with employers to build programs that benefit employees and create a stable, high-functioning workplace. Understanding that an inclusive, values-based culture provides a crucial competitive advantage in the modern workplace, Laura enjoys counseling companies on the development of proactive and equitable pay and diversity practices.

In Laura’s version of the reimagined workplace, attention to human capital issues, especially DEI and pay equity, would be the rule rather than the exception nationwide and she works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize this vision for her clients’ ongoing success. She helps clients understand all issues across the spectrum of their journey, helping to establish regular analyses as well as counseling organizations on implementation and compliance obligations, where applicable. Committed to putting her clients’ organizational goals first and foremost, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication.

Laura also represents companies in OFCCP matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming from OFCCP regulations. She personally oversees the development of hundreds of Affirmative Action Plans for clients each year and is intimately involved in the defense of OFCCP audits. Her approach to compliance is one of facilitation and conciliation while simultaneously advocating in the best interests of her clients.