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Proposed Rule and Guidance Issued for Implementing "Fair Pay and Safe Workplaces" Executive Order

Client Alert | 1 min read | 05.28.15

Today, the Obama Administration published the highly anticipated notice of proposed rulemaking (NPRM) and guidance for implementing the "Fair Pay and Safe Workplaces Executive Order," starting the clock on a 60-day notice and comment period. The NPRM and related guidance (available by PDF here and here and explained in more detail on our government contracts blog) would add onerous labor compliance reporting requirements for contractors and subcontractors on contracts valued over $500,000 (and on non-COTS subcontracts valued over $500,000), inject subjectivity into the contract award process through the addition of "Agency Labor Compliance Advisors" advising the CO with respect to responsibility determinations, limit contractors' right to arbitrate certain employment disputes, and add new "paycheck transparency" requirements for contractors.


Insights

Client Alert | 5 min read | 09.03.26

DOT Final Rule Narrows Airline Delay and Cancellation Reporting Obligation Under FAA Reauthorization Act of 2024

The U.S. Department of Transportation (DOT) published a final rule amending 14 CFR Part 234 that fundamentally changes how airlines report the causes of flight delays and cancellations. Effective October 19, 2026, the rule implements Section 511(b) of the FAA Reauthorization Act of 2024 by creating a new reporting category, the “Section 511(b) category,” for ten specific events that Congress determined are not attributable to airline control. The rule simultaneously narrows the existing "Air Carrier" reporting category by expressly excluding those same ten events....