Important Changes for Federal Contractors

Wednesday, December 8, 2021

Beginning February 1, 2022, supply and service federal contractors must register for a newly established Office of Federal Contractor Compliance Programs (OFCCP) Contractor Portal. Registration will require a contractor’s Federal Tax Identification Number, legal business name, DUNS number and NAICS code. 

Beginning March 31, 2022, and no later than June 30, 2022, supply and service federal contractors must use the Portal to certify that they have developed and maintained an affirmative action program for each of their establishments.  Contractors will not be required to submit their affirmative action programs annually, but only to certify that they have maintained one for each establishment.  If a federal contractor is audited by the OFCCP, it will also use the Portal to upload information requested as part of the audit.

Contractors should also remember that beginning January 30, 2022, the minimum wage for employees working on or in connection with certain new federal contracts is increased to $15 per hour. A “new federal contract” is one that is entered into, extended, renewed or on which an option is exercised on or after January 30, 2022.  The increase applies to employees working on contracts covered by the Service Contract Act, the Davis-Bacon Act, concessions contracts not subject to the Service Contract Act and certain contracts in connection with federal property or land.  This increase does not apply to contracts for the manufacturing or furnishing of materials, supplies or equipment.

Anyone with questions about the above should contact the author of this alert or their Butzel Attorney.

Regan Dahle
734.213.3268
dahle@butzel.com

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