April 8, 2024 | less than a minute read

Pay Transparency is Knocking at Federal Contractor Doors - DoD, GSA, NASA and OFPP Issue Proposed Pay Equity and Transparency Rule

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Farrah Rifelj

Partner, Sub-Practice Leader, Affirmative Action Co-Chair, Diversity, Equity & Inclusion Committee, Management Committee Member

Get in touch

Farrah Rifelj

Partner, Sub-Practice Leader, Affirmative Action Co-Chair, Diversity, Equity & Inclusion Committee, Management Committee Member

The proposed federal regulation incorporates both prohibitions on seeking an applicant's compensation history and using voluntarily provided compensation information in making pay decisions. It also requires contractors to disclose compensation information when advertising for job openings for positions where the hired applicant will perform work on or in connection with a federal contract.

Notably, the proposed rule requires Contractors to flow-down its requirements to all subcontracts at any tier, has no de minimis standard, and would even apply to commercial off the shelf products.