Federal Contractor Update – Minimum Wage Increase, Contractor Portal, Guidance for Educational Institutions


This past month, the Office of Federal Contract Compliance Programs continued with its flurry of activity. Among the actions it has taken are the announcement of the new minimum wage rate for certain covered workers, a new feature on its recently-created Contractor Assistance Portal, and guidance for educational institutions and other contractors with campus-like settings.

Minimum Wage Increase for Government Contractors. Executive Order 13658 established a minimum wage rate, increased annually, for all covered workers performing work on construction contracts covered by the Davis-Bacon Act (DBA); service contracts covered by the Service Contract Act (SCA); contracts to provide concessions (g. food, lodging, fuel, etc.) on federal property; and contracts to provide services (e.g. child care, dry cleaning, etc.) in federal buildings. The DOL has announced the applicable minimum wage increase effective January 1, 2020: $10.80 per hour, with a tipped wage rate of $7.55 per hour. In addition, covered contractors must update the required minimum wage poster as of that same date, which can be found on the DOL website (only the current poster is available now; check again on January 1, 2020 for the updated poster).

Update to Contractor Assistance Portal. As we discussed in our August 2019 E-Update, the OFCCP launched its new Contractor Assistance Portal, intended to improve compliance assistance and increase transparency. This past month, the OFCCP added a new Topics feature to the portal, which allows contractors to post questions for feedback from the contractor community.

Guidance for Educational Institutions.  The OFCCP issued guidance that clarifies the affirmative action program requirements for educational institutions and other contractors with campus-like settings, as well as supporting the White House Initiative on Historically Black Colleges and Universities (HBCUs), as follows:

  • FAQs on AAPs for Campus-Like Settings, providing guidance on whether one or multiple affirmative action programs (AAPs) should be maintained for a multi-building establishment.
  • The Student Worker Directive, providing guidance on whether academic institutions need to include student workers in their AAPs and the support data submitted to OFCCP during a compliance evaluation.
  • The HBCU Webpage, a one-stop shop helping to connect college students with internship, apprenticeship, and entry-level job opportunities as part of the White House Initiative on Historically Black Colleges and Universities.