On July 31, 2014, President Obama signed the Fair Pay and Safe Workplaces Executive Order, which requires both government contracting officers and government contractors to track and coordinate contractor and subcontractor compliance with federal and certain state labor laws starting in 2016. Contractors that have gone through a Department of Labor administrative merits determination or civil adjudication, and may even have fully resolved their compliance problems, will now face further scrutiny and the possibility of additional remedial measures being imposed. This Executive Order follows several other recent employment related Executive Orders applicable to government contractors, all of which have increased costs or compliance obligations for government contractors.
The most significant substantive changes and impact on contractors and subcontractors are discussed below.
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