Redstone Government Consulting Blog | Sheri Buchanan

The McNamara-O’Hara Service Contract Act (SCA), aka Service Contract Labor Standards (SCLS), requires contractors and subcontractors on covered contracts to provide specified wages and fringe benefits to covered employees (i.e., “service employees”). While that may sound fairly straightforward, there are many nuances and complexities that can cause great concern and angst when working toward compliance with the SCA. At the top of the list of these administrative burdens is the appropriate distribution of Health and Welfare (H&W).

If chosen carefully and skillfully, a Human Resources Management (HRM) Technology Solution can significantly improve workplace productivity, enhance compliance, and encourage employee engagement. The various acronyms (i.e., HRM, HRIS, HCM) utilized to describe HR technology solutions often create confusion. Essentially, a robust Human Resource Management system, “HRM” as we will call it, brings together human resources (full life cycle of applicant tracking through onboarding-to-termination), timekeeping, workforce management, payroll, and data analytics all under one technology solution—a comprehensive, full-suite single solution.

Over the last few years, with the uber-competitive labor market and evolving landscape of remote and hybrid work arrangements, I've had many conversations (some feeling more like counseling sessions!) with clients who had become very tired and frustrated with the rising compensation and work-related demands of candidates. These conversations included questions like: When will we see the labor market settle? How can we be profitable when paying rates such as this? What makes sense? Is there any way this would be considered reasonable? Will that be fair to my long-term employees? What we found is those with established and well-structured compensation plans were able to respond to these questions and the challenging scenarios they faced much more efficiently and effectively than those who did not.

The Office of Federal Contract Compliance Programs (OFCCP) has been busy since the start of fiscal year 2023, which began on October 1, 2022. Since this time, they have completed over fifteen investigations that have resulted in large settlements totaling more than ten million dollars. Many of the investigations centered around discrimination in hiring and compensation.

What is the Corporate Scheduling Announcement List (CSAL)?

In this uber competitive labor market, it is more crucial than ever to be creative with compensation and benefits. Compensation programs and retention strategies have expanded beyond base compensation and bonus to include all methods in which employees are rewarded and incentivized. As a Federal Government Contractor, it is especially important to understand the FAR requirements which may impact compensation decisions and to document all processes and procedures related to your compensation program.

Throughout this series, we’ve explored the fundamentals of compliance with the regulations administered by the Office of Federal Contractor Compliance Programs (OFCCP) and many of the components of a written Affirmative Action Plan. In this final blog of the series, we will answer a question frequently asked of us…What do you do with all this information?

As mentioned throughout this series on Office of Federal Contract Compliance Programs (OFCCP) and Affirmative Action (AA), recordkeeping is essential. A particularly important component when developing your AAP , as shown in a previous blog, is Applicant Flow (i.e., records pertaining to each “applicant”). When working with clients, we find that this tends to be the most complex and often confusing information requested. Following are answers to some of the most common questions we are regularly asked:

We hope that the previous blogs have provided a solid explanation as to what an Affirmative Program is and who the Office of Federal Contract Compliance Programs (OFCCP) is. The requirement to maintain a written plan/s and ensure all action items noted within the plan are being executed can be a daunting task. As we begin to steer away from the basics of what the various requirements and components of a written plan are, we will begin to dive into helpful tips and best practices. As shown in the diagram from a previous blog in this series, the establishment of Job Groups and Activity records are critical to establishing a valid Affirmative Action Plan and are therefore worth focusing on.