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Category: Comment Letter

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has filed comments with the White House Office of Federal Procurement Policy (OFPP) and the Federal Acquisition Regulatory (FAR) Council in response to the proposed rule on Pay Equity and Transparency in Federal Contracting. The proposal would require contractors to disclose salary and benefits in advertisements for jobs to be performed under a covered contract, prohibit contractors from using compensation history in making employment decisions, and mandate an employee rights notice.

CWC’s comments do not criticize the proposed rule’s major elements but instead address practical questions and make recommendations for reducing the potential compliance burden. For example, CWC recommended that the rule allow contractors to consider the compensation history of applicants who disclosed their prior pay on their own initiative and of their current employees own initiative and of their current employees who are being considered for transfers or promotions. Furthermore, CWC urged that contractors who act in good faith be given significant flexibility when identifying the specific agency that awarded the contract or issued the solicitation on which an applicant would primarily work.

CWC members can read more here.

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