Two New Challenges for Federal Contractors and Subcontractors
By Jon A. Geier and Emily N. Dillingham
Two recent regulatory actions pose new challenges for federal contractors and subcontractors. First, on May 20, 2010, the Department of Labor (DOL) published its final rule on Notification of Employee Rights Under Federal Labor Law (the Labor Law Rule). The Labor Law Rule implements Executive Order 13496, signed by President Barack Obama on January 30, 2009, and requires covered federal contractors and subcontractors to (i) post both a hard copy and an electronic poster informing their employees of their rights under the National Labor Relations Act (NLRA) and (ii) include a reference to the obligations of the Labor Law Rule in all subcontracts and purchase orders. The Rule takes effect on June 21, 2010.