A new year often brings about new beginnings – and federal contractors across the country may have to face a new normal in 2023 when it comes to paid leave obligations. Given that federal paid leave proposals proved unsuccessful over the past two years, many state and local lawmakers are moving towards enacting family and medical leave policies of their own. Michigan and Minnesota legislatures appear to be at the forefront of this initiative, but they are by no means the only states that will see movement in this area in 2023 given the political composition of other state legislatures. This means that federal contractors subject to Executive Order 13706 may need a refresher not only on their existing paid leave obligations but on the interplay with state and local leave laws that may alter or expand their responsibilities. Here’s what federal contractors need to know as we head into this new era.
What Types of Contracts are Impacted By the Executive Order?
Not all federal contractors are implicated by Executive Order 13706. Generally, if the contractor is also subject to the federal contractor minimum wage regulations (typically through a Davis Bacon Act (DBA) or Service Contract Act (SCA) qualifying contract), they will also be covered by the paid leave obligations. That’s because the definition of covered contractor has purposely paralleled those regulations for the paid sick leave rules.
Employers should first confirm whether their government contracts or subcontracts...
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