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Fair Pay Rules Are Coming

December 2015

Government Contracts Issue Update

The Office of Personnel Management (OPM) most recent semi-annual regulatory agenda reported that the Federal Acquisition Regulatory (FAR) Council is targeting April 2016 for release of the final rule implementing Executive Order 13673, Fair Pay and Safe Workplaces. Wiley Rein has deep experience with these proposed regulatory developments. Most notably, Wiley Rein represented a coalition of defense contractors in assisting the Aerospace Industries Association in commenting on the proposed rule and associated proposed guidance form the Department of Labor. Among other issues, the comments highlighted the host of compliance challenges that contractors will face both before and after implementation of the final rule and guidance. We encourage contractors to take OPM’s agenda as a reminder to review policies, procedures, and data reporting ahead of the final rule’s implementation this coming year.