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ARTICLE · 15 AUGUST 2017

DOL Guts Sick Leave Requirement Complicating Contractor Compliance

Holland & Knight
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Federal contractors will soon encounter a new hybrid Health & Welfare benefit for annual WDs issued by the DOL that will be challenging to apply and may result negative price adjustments...

United StatesGovernment, Public Sector
Eric Crusius
Eric Crusius
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Eric Crusius is an attorney in Holland & Knight's Tysons office

Federal contractors will soon encounter a new hybrid Health & Welfare benefit for annual Wage Determinations (WDs) issued by the Department of Labor that will be challenging to apply and may result negative price adjustments under contracts subject to the Service Contract Labor Standards (SCLS).

Once a year, the Department of Labor (DOL) issues an All Agency Memorandum (AAM) that sets the Health & Welfare benefit (H&W) for new WDs issued for SCLS contracts pursuant to 29 CFR § 4.52. Once a new AAM is released, WDs issued in the coming year reflect the new H&W amount. Those new WDs are eventually added to existing contracts when modified by the agencies.

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