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Service Contract Labor Standards and Pricing Implications Hope Lane & Barbara Connell | March 30, 2016 http://blogs.aronsonllc.com/fedpoint/

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Page 1: Service Contract Labor Standards and Pricing Implications

Service Contract Labor Standards and Pricing Implications

Hope Lane & Barbara Connell | March 30, 2016

http://blogs.aronsonllc.com/fedpoint/

Page 2: Service Contract Labor Standards and Pricing Implications

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Agenda

• What/When/Where/Who• Wage Determinations• Wages and Fringe Benefits• Contract Compliance and the Impact of Recent Executive Orders• Pricing and the Impact of Recent Executive Orders

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What is SCA?

Service Contract Labor Standards Formerly known as Service Contract Act of 1965 (SCA)

•Sets the minimum wages and fringe benefits that contractors and their subcontractors must pay service employees working on covered contracts. Similar to the Davis-Bacon Act (construction) and Walsh-Healey (supply)•Pub. L. 89-286, 79 Stat. 1034; Codified at 41 U.S.C. 67•Amended twice:

–1972 – Successor Employer Obligation § 4(c) –1976 – Extension to White Collar Employees

•Regulations–29 CFR Part 4, Section 4.6, Last major changes 1/30/84–FAR 52.222-41 Service Contract Labor Standards–FAR 52.222-17 Nondisplacement of Qualified Workers

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What is SCA?

• SCA was intended to remove wages as a bidding factor in the competition of federal service contracts; and

• To provide wage protection to service employees

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When Does SCA Apply?

To contracts that are…•From any Federal Agency or any other Federal Government entity or District of Columbia;•To be performed in the U.S, its territories and possessions; •Principally for services (>50% of contract effort);•Performed through the use of service employees; and•In excess of $2,500.

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When Does SCA NOT Apply?

To contracts that are….•For leasing of space•For professional services (performed almost exclusively by employees that meet the exemptions under 29 CFR Part 541)

– Non-exempt employees are a minor factor in contract performance, DOL applies a 10-20% range

•For maintenance, calibration or repair of IT and office equipment•For federally-assisted contracts for services entered into by state governments (e.g. Medicaid, Medicare programs)•Other Statutory exemptions (e.g. construction, freight, carriage)•For communication services covered by the Communications Act of 1934•For public utilities services•For employment contracts with individuals for direct services to a Federal agency•For United States Postal Service contract station operation contracts

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• Johnston Island• Wake Island• The Virgin Islands• Outer Continental Shelf

Islands as defined in the Outer Continental Shelf Lands Act.

• Any State• The District of Columbia• Puerto Rico• Commonwealth of Northern

Mariana Islands• Guam• American Samoa

Where Does SCA Apply?

Geographical LimitsThe SCA applies to all work performed within the United States. For purposes of the SCA, the term “United States” includes:

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How to Determine if SCA Applies to an RFP/Contract?

Requests for Proposal or Contracts incorporating either of the following two clauses:•FAR 52.222-41 Service Contract Labor StandardsFAR (Federal Acquisition Regulations) are the rules and regulations that implement acquisition policies for federal agencies and Contractors

-OR-•29 CFR Part 4, Section 4.6 Labor Standards clauses for Federal service contracts exceeding $2,500

The Code of Federal Regulations (CFR) is a compilation of the regulations that implement federal laws

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How to Determine if SCA Applies to an RFP/Contract?

ANDArea Wage Determination (AWD)•Attached as an exhibit; or•By reference (not recommended)

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What if SCA is NOT in Contract?

The “Christian Doctrine”•Mandatory clauses automatically become part of the contract despite their omission from the contract.FAR 22.1006•Details the mandatory clauses for service contracts government by the Service Contract Labor Standards; therefore, they would be included in contracts even if they are inadvertently omitted.

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Who Interprets & Administers It?

• SCA is enforced solely by DOL• Contracting agencies have certain responsibilities but no authority.• If contract is subject to SCA but agency does not specify SCA in

contract, DOL will notify agency to insert SCA contract clauses & applicable Wage Determinations.

• Reliance on advice from contracting agency officials is not a defense against a contractor’s back wages under the Act (29 CFR 4.187 (e) (5)).

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Employees who qualify for exemption as executive, administrative or professional as defined by 29 CFR Part 541…

•Executive– Must be paid on a salary basis at

least $455/week, supervise 2 or more workers, exercise authority; and spend most of their time doing so

•Administrative– Must be paid on a salary basis at

least $455/week, make decisions of importance and significance using independent judgment and discretion, and spend most of their time doing so

• Professional– May be paid salary, fixed fee, or

hourly basis at least $455/week, perform work primarily requiring advanced knowledge, predominantly intellectual, customarily acquired by a prolonged course of specialized intellectual instruction (e.g. college level); and exercise independent judgment and discretion

• Computer Professional– May be paid on a hourly basis if paid

more than $27.63/hour; otherwise,– Must be paid on a salary basis at

least $455/week– Perform higher level duties (e.g.

design, development work with greater responsibilities)

Which Employees are Exempt from SCA?

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DOL Proposed Rule – Defining and Delimiting the Exemptions for Executive, Administrative, Professional, Outside Sales and Computer Employees

• Released June 30, 2015• Proposed increase to current minimum salary for exempt employees

from $455/week ($23,660/year) to a minimum of approximately $970/week ($50,440/year)

• 113% increase!• DOL estimates around 5 million additional employees to become

non-exempt• DOL targeting July 2016 release of final rule, effective within 60-90

days after publication

Will result in fewer exempt employees, increasing the number of employees subject to SCA!

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What is an Area Wage Determination (WD)?

A WD sets the minimum wages and fringe benefits for job classifications for a specific geographical region.•Minimum hourly Wage for the job position•Minimum hourly Health & Welfare Benefit•Minimum annual Vacation Benefit•Minimum Holiday BenefitNote: As a rule, SCA does NOT provide for Sick Leave Benefit. (That benefit if given, is governed by the Contractor’s company policy. An exception to this rule – Collective Bargaining Agreements (CBAs) may contain a Sick Leave requirement or Sick Leave may be mandated by Presidential Executive Order 13706)

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Types of SCA WDs

Area (Standard) WDs•Generic, issued per locality, reflect prevailing wages•Locality is county or group of counties, or larger•Area WDs list over 200 worker classificationsNon-Standard WDs•e.g., fast food, elevator maintenance, diving, moving household goods, urinalysis, etc.•Reflect wages prevailing in specific industry

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Types of SCA WDs

Collective Bargaining Agreement (CBA) WDs– Based on predecessor collective bargaining agreements under

SCA Sec. 4(c) Contract-Specific WDs– WDs issued by specific request to DOL for unique (often sole-

sourced) contracts– Cannot be used for any other contract

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SCA Directory of Occupations

• For Standard and Non-Standard WDs, the Directory defines classifications and duties

• Published by DOL• Contains federal grade equivalent levels• Located on the Library Page at www.WDOL.gov

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Where do You get SCA WDs?

• For Contractors – look in your contract– WDs must be incorporated into the contract by the contracting

officer to be applicable• Contracting officers obtain WDs from www.wdol.gov– WDOL is a menu-driven database for contracting agencies to

use– Accessible by the general public for informational purposes only

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SCA Wage Determination

• DOL issues two Standard WDs for each locality– odd-numbered– even-numbered

• Labor classifications, wage rates, H&W rate, holidays and vacation benefits are the same on both WDs.

• However, the method required to be used by employers in providing the H&W benefit is different for each WD…

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SCA WD – Odd Numbered

• Odd-numbered WDs (i.e., 2005-2011) require a contractor to pay the H&W rate for all hours paid each week (work time and paid leave time) up to a maximum of 40 hours each week

• Referred to as the “Fixed Cost” – Most frequently used

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SCA WD – Even Numbered

• Even-numbered WDs (i.e., 2005-2020) require a contractor to pay a minimum contribution for benefits costing an average of the H&W rate for all hours worked (including overtime hours) by service employees on the contract

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Updates to Wage Determinations

• No increase to minimum wages for a number of years. DOL did not have a standard upon which to base regular wage increases.

• New source: Occupational Employment Statistics (OES) survey published by Bureau of Labor Statistics (BLS)

• More WDs issued due to OES survey’s smaller geographic areas• WDOL.gov – Library of Links and Related Information

– 2015 SCA Crosswalk for new WDs

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Updates to Wage Determinations, Cont.

• To avoid a disruptive impact on wages due to transition to OES survey, DOL will implement new methodology gradually-– DOL will maintain existing wage rates as a floor– DOL will cap any increases in wage rates at 10% per WD rate

update• Updates to Directory of Occupations– Updates to existing occupational definitions– 27 new classifications added

All Agency Memo No. 218

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Common Misconceptions

• “I pay higher than market wages.”• “I have a healthy benefits package.”• “I pay more than is required, so it offsets the health and welfare

deficit.”• “They’re independent contractors, its not my problem.”• “The labor category doesn’t appear in DOL’s Directory of

Occupations, so it is not SCA covered.”• “DOL released a new WD, I need to make payroll changes.”• “Temporary employees don’t earn benefits.”

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Payment of Wages

• The prevailing rate established by the contract Wage Determination (WD) is the minimum rate of pay.

• Wages and hours worked must be calculated on a fixed and regularly recurring “work week” of seven consecutive 24-hour workday periods.– Payroll Records must be kept on this basis– A bi-weekly or semi-monthly pay period may be used if advance

notice is given to affected employees. • No distinction is recognized in wage compensation requirements

between full-time, part-time, and temporary employees.

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SCA Fringe Benefits (FBs)

Prevailing WDs identify fringe benefits•Vacation, generally stated as X weeks/year•Holidays, generally stated as X days/year•Health and Welfare (H&W) Benefits– Stated as an hourly amount– Issued nationwide (one rate for all localities, except Hawaii)– Revised annually by DOL approximately every June 1st

(applicable to contract awards/options issued thereafter)Significant 2015 HW increase due to Affordable Care Act (ACA). We

anticipate other significant increases may occur this year.

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SCA Vacation Benefits

Vested and becomes due after the SCA employee’s Anniversary date determined by total length of time:• Working for present employer in any capacity• And/or working for predecessor contractors in performance of similar

services at the same facility.

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SCA Holiday Benefits

• Employee is entitled to holiday pay if they work in or receive sick/vacation pay in the holiday workweek.

• Holiday Pay is generally not applicable to days in which the Federal Government is closed by proclamation, such as the day before Christmas or on snow days, in other words, any holiday not named in the Contract or Wage Determination.

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Part-Time & Temp Employees

Part-time employees must be paid a proportionate amount of the mandated fringe benefits.Examples:

– A full-time employee is entitled to 2 weeks (80 hours) of vacation. A part-time employee working a regular schedule of 20 hours per week would be entitled to ½ (40 hours) the paid vacation benefits at the end of the anniversary year.

– The same part-time employee would be entitled to ½ the holiday pay benefits (e.g., 4 hours)

– Temporary or part-time employees working irregular schedule of hours are entitled to holiday pay proportionate to the number of hours worked in the week prior to the holiday.

– All part-time and temporary employees would be entitled to the same hourly rate of the health & welfare (e.g. $4.27/hour).

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SCA H&W Benefits

• Reference 29 CFR Part 4, Sec. 4.175 (a) and (b)• Under both types of Standard WDs, employers discharge the H&W

requirement by– Providing bona fide benefits to the workers– Or cash payment for the H&W rate– Or paying a combination of cash and bona fide benefits– Currently $4.27 hour

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Payment H&W Benefits

• Cash payments in lieu of fringe benefits must be paid on regular pay date (29 CFR § 4.165(a))

• Payments into bona fide FB plans must be made no less often than quarterly (29 CFR § 4.175(d))

• Excess wages over WD minimum may not be credited toward H&W requirements (29 CFR § 4.170)

• Excess FB costs may not be credited toward wage requirements (29 CFR § 4.167)

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• Health Insurance• Dental Insurance• Life Insurance• Accidental Death &

Dismemberment• Disability Insurance• Vision Care Insurance• Sick Leave Paid, if not required by

CBA, WD, or mandated by Executive Order 13706 or state/municipal law

• Employer Contributions to 401(k) Savings Plan

• ESOP, Pension Plan, or Thrift Plan

• Educational Assistance, if not required by the job

• Severance Pay Plans• Paid Vacation or holiday in

excess of WD requirement• Jury Duty, Military, bereavement,

and other paid leave in excess of that required by law

• Cash paid in lieu of benefit plans

What Benefits Satisfy H&W

Typical Benefits that satisfy the H&W requirement are:

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Benefits NOT Satisfying H&W

Typical Benefits NOT ELIGIBLE for Satisfying the H&W requirement are:

• Statutory payments (FICA, Unemployment Insurance, Worker’s Compensation)

• Benefits provided for the benefit or convenience of the company:• Relocation• Incentive Awards• Tools• Uniforms, not required by WD• Social functions, gifts, celebrations• Administrative costs incurred in providing benefits• Paid leave or sick leave required by the CBA, WD, or Executive Order

13706, or state/municipal law

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Collectively Bargained FBs

• Based on Collective Bargaining Agreement (CBA)• Required to be paid by successor contractor under section 4 (c) of

SCA• FBs specifically stipulated in CBA are not required. Equivalent

benefits may be provided• Cash equivalent payments can be used to offset the FBs due

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Contract Compliance and the Impact of Recent Executive Orders

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Who is Liable for Compliance?

The Prime Contractor•Must “flow down” the applicable SCA contract clauses to subcontractors (includes independent subcontractor – i.e., 1099s) (29 CFR 4.155)•“Joint and severally” liable for subcontractor’s non-compliance with SCA (29 CFR 4.114(b))

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Costly Assumption

“We have a healthy benefits package, our fringe rate is 32%.”

•Odd WDs - Complying with HW requirements is based on the cost of actual benefits taken by each employee, not firm-wide fringe cost. •Even WDs - Complying with HW requirements is based on the average cost of benefits taken by all covered employees, not firm-wide fringe cost.

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How to Implement a Compliance Program?

• Keeping an excel spreadsheet which tracks wages and benefits in comparison to SCA wage determination requirements.

• Factors that add to the complexity of compliance:– Multiple pay rates and/or positions during the year– Multiple benefits costs during the year– OCONUS deployments not subject to SCA

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Why Should I Comply?

SCA Sanctions & Remedies (41 U.S.C. 6705)For violations, the U.S. Government may….•Withhold from payment for the contract a sum adequate to pay back wages or fringe benefits to underpaid employees;•Bring legal action against the Contractor or surely for the amount of underpayment; •Terminate contract and hold Contractor liable for any resulting cost to the government; and•Not award contracts to a violator for up to 3 years (debarment).Representations of preceding 3-year SCA compliance violations influence proposal evaluations (Fair Pay and Safe Workplaces E.O. 13673)

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Comply with SCA or Go to Jail

“Business owner was sentenced to 8 years in prison and ordered to pay more than $2 million in restitution for role in a complex,

multiyear scheme to steal employee benefit contributions required under the McNamara O’Hara Service Contract Act (SCA)”

OIG Investigations Newsletter Volume IUnited States v. Tucker et al

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DOL Investigation Issues

• Are SCA regulations included in contract?• Are the SCA poster & WD, including any conformance actions,

posted at the site or made available to employees?• Does WD contain necessary labor categories?• Is a conformance necessary?• Are employees properly classified (WD & FLSA)?• Are fringe benefits properly paid?• Is Overtime correctly paid under the FLSA, if appropriate?• Has employer kept accurate payroll records?

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Pricing and the Impactof Recent Executive Orders

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SCA Basic Pricing Elements

• Labor (WD or E.O. Minimum Wage)• Fringe

– Health & Welfare (generally priced on billable hours but paid on all hours up to 40/wk)

– Vacation– Holiday– Sick Leave (as mandated by Executive Order 13706)– Other Leave (if offered)– Statutory payments (FICA, unemployment insurance workers

compensation)• Overhead• General & Administration (G&A)• Profit

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FAR 52.222-55, Minimum Wages Under Executive Order 13658

• Final rule announced on October 2, 2014• Establishes minimum wage ($10.15 effective January 1, 2016 –

December 31, 2016) for employees working on federal contracts– Includes workers performing on or in connection with

contracts covered by the clause whose wages are governed by SCA, FLSA, or DBA

– Includes non-direct personnel performing duties necessary to support covered contracts (e.g. Receptionist at SCA contract-dedicated contractor site facility) as long as they spend more than 20% of their work hours in a given workweek performing in connection with covered contracts (see next slide).

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FAR 52.222-55, Covered Contracts

• Affects solicitations issued on or after January 1, 2015• Covered by SCA, Fair Labor Standards Act (FLSA), or Davis Bacon

Act (DBA);- And -

• Contract must fall into one of the following categories:– Procurement contracts for services or construction covered by

Davis Bacon Act (DBA)– Service contracts covered by SCA– Contracts for concessions– Contracts in connection with federal property or lands related to

offering services for Federal employees, their dependents, or the general public

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FAR 52.222-55, Continued

• Flowdown contract clause to all tiers of subcontractors• DOL will have investigation and enforcement authority– Remedy suspected violation though conciliation (informal

remedial measure)– Pay all unpaid wages pursuant to DOL’s findings– DOL may direct withholding of payments until violation resolved– Potential suspension or debarment

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SCA Price Adjustments

• When the contract is modified to incorporate a new WD or when the Secretary of Labor publishes a new FAR minimum wage rate, a contractor may be entitled to a change in contract price– New (most current) SCA rates will be incorporated into the

contract at each option, extension, substantial change in scope of work, or no less than every two years if not funded annually.

– Secretary of Labor determines FAR minimum wage rate yearly

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SCA Price Adjustments

• Under cost-reimbursable contracts, contract price relies on “reasonable, allowable, and allocable” determinations

• Under fixed-price contracts, a contract price can be changed only under– The Changes Clause, OR– The SCA/FLSA Price Adjustment Clause (FAR 52.222-43)

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E.O. 13673, Fair Pay and Safe Workplaces

• Rule Proposed May 28, 2015• Contractors bidding on procurement contracts in excess of $500,000 will be

required to “represent to the best of [their] knowledge and belief, whether there has been any administrative merits determination, arbitral award or decision, or civil judgment” rendered against the contractor within the preceding 3-year period for violations of several labor laws including SCA.

• This information, along with Agency Labor Compliance Advisor’s (ALCA) recommendation, will be factored into the CO’s responsibility determination. CO makes ultimate decision.

• Similar information will need to be collected from and disclosed on behalf of subcontractors of all tiers on subcontracts valued over $500,000 (other than COTS items). Collection of this data needs to be incorporated into subcontracting agreements.

Contractormisconduct.org – Search “Kevin v. Lockheed Martin”

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Disclose Violations for 14 Federal Labor Laws

• —The Fair Labor Standards Act, 29 U.S.C. chapter 8.• —The Occupational Safety and Health Act (OSHA) of 1970.• —The Migrant and Seasonal Agricultural Worker Protection Act.• —The National Labor Relations Act.• —40 U.S.C. chapter 31, subchapter IV, formerly known as the Davis-Bacon Act.• —41 U.S.C. chapter 67, formerly known as the Service Contract Act.• —E.O. 11246 of September 24, 1965 (Equal Employment Opportunity).• —Section 503 of the Rehabilitation Act of 1973.• —The Vietnam Era Veterans' Readjustment Assistance Act of 1972 and the Vietnam Era

Veterans' Readjustment Assistance Act of 1974.• —The Family and Medical Leave Act.• —Title VII of the Civil Rights Act of 1964.• —The Americans with Disabilities Act of 1990.• —The Age Discrimination in Employment Act of 1967.• —52.222-55 - Minimum Wages Under Executive Order 13658Equivalent state law violations must be disclosed

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E.O. 13673, Fair Pay and Safe Workplaces, Cont.

• During contract performance, contractors performing work on covered contracts and subcontracts will be required to update disclosures every 6 months

• Information disclosed may result in Government action including decision not to exercise a contract option, contract termination, or referral to the agency suspending and debarring official

• CO will request that labor law violation information is input into System for Award Management (SAM)

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E.O. 13673, Fair Pay and Safe Workplaces, Cont.

• Implementation will occur on new contracts in stages, on a prioritized basis, after final rule

• Final rule should be released in April or May

SCA compliance is more crucial to business success than ever before!

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E.O. 13706, Establishing Paid Sick Leave for Federal Contractors

• E.O. released September 7, 2015, proposed rule issued February 25, 2016

• Establishes up to 7 days (56 hours) of sick leave per year– Earned at the rate of 1 hour of paid sick leave for every 30 hours

worked on contracts subject to SCA, DBA, concessions contracts, & contracts in connection with Federal property or lands

• Accrued sick leave carries over from year to year• Unused paid sick leave is not required to be paid out upon

separation, but contractors must reinstate sick leave for employees that are rehired by the same contractor or a successor contractor within 12 months of job separation

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E.O. 13706, Establishing Paid Sick Leave for Federal Contractors, Cont.

• Applies to prime and all tiers of subcontractors• Exempt employees working on SCA-covered contracts are required

to receive sick leave.• Includes non-direct personnel performing duties necessary to

support covered contracts (e.g. Receptionist at SCA contract-dedicated contractor site facility) as long as they spend more than 20% of their work hours in a given workweek performing in connection with covered contracts

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E.O. 13706, Establishing Paid Sick Leave for Federal Contractors, Cont.

• Sick leave provided to fulfill requirements of the E.O. may not credit towards HW under SCA. Sick leave provided in addition to required amount under the E.O. may count towards HW requirement.

• Comment period extended to April 12, 2016!

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About Aronson LLC

Aronson LLC provides a comprehensive platform of assurance, tax, and consulting solutions to today’s most active industry sectors and successful individuals. For more than 50 years, we have purposefully expanded our service offerings and deepened our industry specialties to better serve the needs of our clients, people, and community. From startup to exit, we help our clients maximize opportunity, minimize risk, and unlock their full potential.

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About Aronson LLC

• Thinking ahead for clients for more than 50 years• 225+ professionals located in Rockville, MD• 80+ professionals dedicated to supporting government contractors • Aronson helps clients rethink the way they approach their business

through innovative, industry-specific services and advice:– Audit, Assurance and Tax– Deltek Systems and Outsourcing– Financial and Contract Compliance– GSA Schedules

• www.aronsonllc.com/blogs/fedpoint/ – News and trends and insight for today’s savvy government contractor

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Awards / Accolades / Affiliations

The Gazette of Politics & Business Exceptional 53 Business Award In 2012, Aronson received the PB53 award for the third year in a row. The program acknowledges the top businesses and organizations in Maryland based on criteria that includes the company’s annual revenue, employee growth, noteworthy product or service innovations, community service efforts and more.

Accounting Today Top Firm In 2013, Aronson was once again named to Accounting Today’s list of the top 100 firms in the country. Accounting Today is a leading provider of online business news for the tax and accounting community.

Washington Business Journal Top 25 Aronson is ranked #12 on the Washington Business Journal’s Top 25 Accounting Firms in the DC Metropolitan area.

INSIDE Public Accounting Top 100 Once again, Aronson has earned a spot in the top 100 of this prestigious list, released by INSIDE Public Accounting. This is the longest running, most comprehensive and accurate independent analysis focusing on management and operations of America’s large local, regional and national firms.

Washington Business Journal Best Places to Work Aronson has been recognized five times as one of the Metro area’s “Best Places to Work.” The award recognizes a company’s achievements in creating a positive work environment that attracts and retains employees through a combination of employee satisfaction, working conditions and company culture.

Montgomery County Chamber Corporate Social Responsibility AwardIn 2010, Aronson was honored to receive the MCCC’s Corporate Social Responsibility Award based on the depth and breadth of the company’s energetic commitment to support young people, in the areas of education, housing and health.

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Hope Lane, CPA, leads Aronson LLC's Government Contract Consulting practice. With more than 20 years of broad-based experience in the government contracting arena, she is well-known as one of the industry's most knowledgeable thought leaders in contract-related financial compliance and contract administration.Exclusively focused on government contracting, Hope possesses in-depth understanding and hands-on expertise. Prior to joining Aronson, she served in financial management positions with several regional federal contractors. Often described by her peers as forward-thinking, Hope is able to go beyond what a client asks for to deliver precisely what they need.As an avid advocate for the government contracting industry, Hope is a guest speaker and lecturer for associations and industry trade groups and a featured speaker at Aronson's executive briefings. She also serves as editor-in-chief of Aronson's Fed Point blog. As a leader in the firm, Hope advocates for continuous growth and mentorship and encourages others in the practice to innovate for the benefit of their clients.Hope earned her bachelor's degree in accounting from the University of North Carolina at Charlotte and is actively involved in professional organizations like the Professional Services Council, National Contract Management Association and Women Impacting Public Policy.

Partner, Government Contract Services Group

301.231-6266

[email protected]

Hope Lane, CPA

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Barbara Connell is a Senior Consultant in Aronson LLC's Government Contract Services Group, where she works with government contractors to provide customized solutions that ensure success and compliance. As a Senior Consultant, Barbara assists clients with GSA Schedule contract acquisition and maintenance, Service Contract Act compliance, preparation of budgeted indirect rates and submission of incurred costs and a variety of government contract compliance areas.As an expert in her field, Barbara is a regular contributor to Aronson's Fed Point blog and she is a featured speaker for Aronson on Service Contract Act compliance. Barbara earned a bachelor's degree from the Pennsylvania State University, where she majored in marketing with a minor in information systems management.

Senior Consultant, Government Contract Services Group

240.364.2657

[email protected]

Barbara Connell

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301.231.6266

Contact Hope Lane / Aronson LLC

[email protected]

https://www.linkedin.com/in/hopelanecpa

https://twitter.com/Aronsonllc

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240.364.2657

Contact Barbara Connell / Aronson LLC

[email protected]

https://www.linkedin.com/in/barbaraconnell

https://twitter.com/Aronsonllc