New small biz provisions in effect
The new year is a good time to review new and recent changes in regulations for small business federal contractors in 2016.
The bad news is that there are a number of complex changes to keep track of. The good news is that some monetary thresholds have been raised, resulting in fewer small businesses being affected.
Here is an overview:
Pay Transparency - for contracts over $10,000. Went into effect. on Jan. 11.
Orders that contractors may not discriminate against employees or applicants because they discuss or disclose their own or another employee’s pay. Human resources employees are exempt.
Section 503 requirements - Equal opportunity and affirmative action for disabled employees and applicants. Applies to contracts of $15,000 and up (raised from $10,000 as of Oct. 1, 2015).
Having a written affirmative action plan applies to contracts of $50,000 and up.
The updates to Sect. 503 include setting a 7% goal for percentage of disabled workers; collecting data on disabled applicants and hires; inviting applicants to self-identify as disabled; incorporation of an equal opportunity clause in subcontracts; and allowing the government to review compliance documents.
More Information: OFCCP Section 503 Fact Sheet: http://www.dol.gov/ofccp/regs/compliance/section503.htm
OFCCP Infographic: http://goo.gl/QOzPC4
BLR brief: https://goo.gl/XRzwy3
Bracell & Giuliani LLP analysis: http://goo.gl/YHnyqD
VEVRAA - Requirements for nondiscrimination and affirmative action for veteran hiring and employment. Affects federal contracts of $150,000 and up, raised from $100,000 and up on Oct. 1, 2015.
More Information: OFCCP Infographic: http://goo.gl/QOzPC4
$10.15 minimum wage - Increased from $10.10 on Jan. 1 for covered federal contracts and subcontracts. Tipped employee minimum wage rose from $4.90 to $5.85 per hour.
Felony Convictions and Tax Liability - Interim rule goes into effect on Feb. 26. Requires that federal contractors will be required to disclose whether they have had any felony convictions in the last two years and whether they have delinquent federal tax liability that is unpaid and not under appeal.
More Information: FisherBroyles analysis: https://goo.gl/ttBUib