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Angela B. Styles

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Not Your Grandfather’s Suspension & Debarment: How Contractors Can Prepare For and Defend Against Today’s Exclusions

Posted in Legal Developments, Suspension & Debarment
Suspension and debarment practice in 2017 is very different than it was just five or 10 years ago, and it continues to evolve.  Historically active programs, such as the Department of the Air Force, show few actions initiated in the last three months, while the Environmental Protection Agency has been heavily involved in excluding contractors… Continue Reading

Join Crowell & Moring for our Webinar “Building a Border Wall: Opportunities, Contractual Risks, and Business Considerations” on Tuesday, April 25th

Posted in Webinar
Join us today for our webinar Building a Border Wall: Opportunities, Contractual Risks, and Business Considerations. The Trump administration published two contract solicitations for the design-build of a “border wall” between the U.S. and Mexico. The RFPs (linked here and here) contemplate a multiple-award, multiple-phase approach for acquiring prototypes and, eventually, full construction.  A team… Continue Reading

State of Suspension/Debarment: FY2016 Statistics and the Impact on Small Businesses

Posted in Suspension & Debarment
Changes in suspension and debarment data reported by the government can provide the American public with substantially more insight into the types of entities (and individuals) excluded through suspensions, proposed debarments, and debarments, including that the overwhelming majority of excluded companies are small businesses.  These changes likely show that more than 90 percent of the… Continue Reading

Significant Developments for Contractors in the Twilight of the Obama Administration

Posted in GSA Schedule/Commercial Items, Labor & Employment, Legal Developments
The final year of the Obama Administration has seen a flurry of activity that will affect the government contracting community.  Appearing on WJLA’s Government Matters program (available here at govtmatters.tv), Crowell & Moring Chair Angela Styles discussed some of the latest changes that will impact industry including the GSA’s final rule on transactional data reporting;… Continue Reading

Administration Walks Back “Economic Significance” Designation of New Rules

Posted in Labor & Employment, Legal Developments
In the latest twist to the Administration’s roll-out of the new “Fair Pay and Safe Workplaces” rules, OIRA now identifies the rules as Economically Significant (a change from several days ago, discussed here), which means that the administration will have to provide a more detailed assessment of the likely benefits and costs of the regulatory… Continue Reading

Wait, What? Administration Now Designates “Fair Pay and Safe Workplaces” as Not Economically Significant

Posted in Labor & Employment, Legal Developments
In a sign that the Obama Administration may be preparing to rush the publication of the FAR Council’s final rules implementing the “Fair Pay and Safe Workplaces” executive order in order to avoid timing problems associated with the Congressional Review Act, the White House’s Office of Information and Regulatory Affairs (responsible for reviewing the rules… Continue Reading

“Fair Pay and Safe Workplaces” Rules Head to White House for Final Review

Posted in Ethics & Compliance, Labor & Employment
On May 4, 2016, the FAR Council’s draft final rules and the Department of Labor’s draft final guidance implementing the “Fair Pay and Safe Workplaces” Executive Order arrived at the White House’s Office of Information and Regulatory Affairs (OIRA) for review, setting in motion the final steps prior to the issuance of burdensome new compliance… Continue Reading

Gesundheit: Proposed Rule Would Mandate Paid Sick Leave for Federal Contractors

Posted in Labor & Employment
On February 25, the Obama Administration published a proposed rule implementing Executive Order 13706, Establishing Paid Sick Leave for Federal Contractors (previously discussed here). The proposed rule, which the Department of Labor estimates would impact 828,000 federal contractor employees (including approximately 436,700 employees who currently receive no paid sick leave and 391,400 employees who receive… Continue Reading

Not So Fast: Congress Gives DoL the Heisman on “Fair Pay” Funding

Posted in Labor & Employment
The FY 2016 Omnibus Appropriations bill, passed on December 18, 2015, did not appropriate funds to establish an Office of Labor Compliance within the Department of Labor in order to implement the “Fair Play and Safe Workplaces” Executive Order, as requested by the Obama Administration. By declining to appropriate the requested funds, Congress pumped the… Continue Reading

Save the Date: Final Rule for Fair Pay and Safe Workplaces Set For April 2016

Posted in Labor & Employment
On Nov. 19, 2015, OMB released the fall 2015 regulatory agenda of regulations currently under development, listing April 2016 as the target for publication of the final rule implementing the “Fair Pay and Safe Work Places” executive order. The final rule, which is likely to be challenged in court by contractors and industry trade groups,… Continue Reading

Nothing to Sneeze at: Obama Administration Issues 13th EO Targeting Federal Contractors

Posted in Labor & Employment
On September 7, the Obama Administration issued a new executive order requiring that federal government contractors provide paid sick leave to employees, the latest in a series of EOs targeting federal contractors, which have to date resulted in 16 new regulations (previously discussed here, here and here).  According to the White House, “[b]eginning with new… Continue Reading

Under Siege: Trade Associations Rap White House for Flood of EOs Targeting Contractors

Posted in Labor & Employment
In an August 3 letter to the White House, four trade associations (the AIA, PSC, NDIA, and ITIC) requested “on behalf of the thousands of companies … that no further presidential directives primarily focused on government contractors be issued for the foreseeable future.”  The letter (linked here) cited a dozen recent executive orders related to… Continue Reading

Comment Period for “Fair Pay and Safe Workplaces” Extended Again

Posted in Labor & Employment
In an August 3 letter to eight committee and subcommittee chairs, the FAR Council and the Department of Labor indicated that the comment period for the “Fair Pay Safe Workplaces” proposed FAR Rule and related DOL Guidance would be extended to August 26 (from the current date of August 11, 2015).  On July 15, as… Continue Reading

FAR Council and DOL Extend “Fair Pay and Safe Workplaces” Comment Period

Posted in Labor & Employment
In response to several requests from industry to extend the a 60-day comment period for the proposed rulemaking (NPRM) and guidance implementing the “Fair Pay and Safe Workplaces Executive Order,” the FAR Council and the DoL have extended the comment period to August 11, 2015 (from the current date of July 27, 2015). As discussed… Continue Reading

Join Crowell & Moring for a Webinar on the New “Fair Pay and Safe Workplaces” Proposed Rule and Guidance

Posted in Labor & Employment
Please join us on Wednesday, June 10, 2015, from 1:00 p.m. – 2:00 p.m., as Crowell & Moring presents the webinar, “Fair Pay and Safe Workplaces Proposed Rule and Guidance: What You Need to Know.” On May 28, 2015, the Obama Administration published the highly-anticipated proposed FAR rule and proposed DOL guidance implementing the Fair… Continue Reading

Obama Administration Issues Proposed Rule and Guidance for Implementing “Fair Pay and Safe Workplaces”

Posted in Labor & Employment
On May 28, 2015, the Obama Administration published the highly-anticipated Proposed Rule and Proposed Guidance implementing the “Fair Pay and Safe Workplaces” Executive Order, (E.O.) which President Obama issued on July 31, 2014. The proposed rule adds a new subpart to the Federal Acquisition Regulations (FAR) – subpart 22.20 “Fair Pay and Safe Workplaces” –… Continue Reading

GSA Announces Changes in its Contractor Assistance Visits

Posted in GSA Schedule/Commercial Items
The General Services Administration (“GSA”) is rolling out two modifications to its Contractor Assistance Visits (“CAVs”), in-person or virtual meetings between GSA’s Industrial Operations Analysts (“IOAs”) and GSA Schedule holders to assess compliance, identify potential problems, and test the contractor’s system controls and processes.  Tom Brady, the Director of the Supplier Management Division, GSA Office… Continue Reading

OMB and DoL Direct Agencies to Appoint Labor Compliance Advisors Pursuant to “Fair Pay” EO

Posted in Labor & Employment
On March 5, OMB and DoL circulated a Memorandum to federal agencies regarding the “Fair Pay and Safe Workplaces” Executive Order (previously discussed here, and here), providing “guidance” with respect to the Labor Compliance Advisor role created by the EO, and directing agencies to designate within 90 days a senior-level official to serve as LCA. … Continue Reading

Suspension and Debarments on the Rise and Likely to Increase Further, ISDC Reports to Congress

Posted in Suspension & Debarment
On March 5, the Interagency Suspension and Debarment Committee (“ISDC”) released a consolidated report to Congress on suspension and debarment developments for FY12 and FY13. Issued in the face of continued legislative pressure to utilize suspension and debarment, the report documents an overall rise in the number of suspensions and debarments – from 4,639 in… Continue Reading

C&M Lawyers Conduct Live Webinar on Sequestration on Thursday, July 12

Posted in Legal Developments
On Thursday, July 12, 2012 at 1:00 p.m. (Eastern time), Crowell & Moring government contracts and labor attorneys Angela Styles, Kris Meade, Steve McBrady and Steve Rice, along with senior policy advisor Mike Gill, will conduct a webinar entitled “Sequestration: Preparing for Unprecedented Cuts to Federal Spending,” in conjunction with L2 Federal Resources. During this… Continue Reading