The paid sick leave requirements mandated by former President Obama’s Executive Order (E.O.) 13706 and the Department of Labor’s (DOL) implementing regulations began to go into effect for covered federal contracts entered into after January 1, 2017. For covered contractors, the rule’s requirements are complex and burdensome, and employers had expressed some hope that the Trump Administration would initiate steps to modify or rescind the rule.  

As time goes by, however, it appears increasingly likely that the contractor paid sick leave rule is here to stay, at least for now. This reality was further confirmed recently when DOL issued an “All Agency” memorandum addressing the interaction of paid sick leave and fringe benefits required under the federal Service Contract Act (SCA).

DOL’s memo establishes the health and welfare benefit rates for SCA contracts, and establishes a new, lower health and welfare benefit rate for contracts covered by the paid sick leave rule.

A copy of DOL’s “All Agency Memorandum 225” is available here.