Download - 2014 ILG Annual Conference: Beyond the AAP
Learning from the Legacy, Focused on the Future
2014 ILG Annual Conference: Beyond the AAP
August 6, 2014
Connie N. BertramProskauer Rose LLP
Katharine ParkerProskauer Rose LLP
Topics for Discussion
Whistleblower protections for contractor employees
Drug-free workplace obligations Restrictions on arbitration agreements
and programs New FAR provision concerning Human
Trafficking Wage and hour developments Enforcement of restrictive covenants Defending litigation claims by contractor
employees
Whistleblower Protections for Contractor Employees
Renewed Focus on Whistleblower Claims
New amendments and legislation Recent developments may make dismissal
and summary judgment less likely Pleading standards Expansion of definition of protected activity Nexus to scope of statute
Believed to have more “traction” with juries Awards generally higher than EEO
discrimination and state law claims Generally provide for reinstatement, “make-
whole” remedies, punitive and/or liquidated damages, and attorneys’ fees
Alternative claims/remedies and forums available, including bounty claims
Three Prongs of FCA Enforcement
“Qui Tam” Cases Under the FCA
The False Claims Act (FCA) imposes liability for treble damages plus penalties for knowingly submitting or causing the submission of false claims to the U.S. Government
A “qui tam” suit is an FCA suit initiated by a whistleblower or “relator” who sues on behalf of the United States Whistleblower files lawsuit under seal DOJ investigates and decides whether to
intervene Relator can proceed without DOJ involvement Relator receives a 15% to 30% share of
government recovery
FCA Also Prohibits Retaliation Against Employees
Prima Facie case: Protected activity Adverse action Because of protected activity
Burden shifts to articulate legitimate, non-retaliatory reasons
Can overcome by showing pretext and intent to retaliate
Business judgment rule a key factor in many rulings
Remedies: Reinstatement, double back pay, and special
damages including attorneys’ fees Compensatory damages in some courts
Developing Issues – Protected Activity
Protected activity prior to FERA (2009) amendments: Section 3730(h) protected “acts … in furtherance of” a
qui tam action Plaintiff need not prove actual violations of FCA Courts required notice of “distinct possibility” of qui tam
litigation (Glynn v. EDO Corp., 710 F.3d 209 (4th Cir. 2013))
Protected Activity after amendments: Section 3730(h) now protects “… lawful acts … in furtherance of an action … or other efforts to stop one or more violations” of the FCA
Must plaintiff still notify employer of “distinct possibility” of qui tam suit?
National Defense Authorization Act
DOD Contractor Protections Prior to NDAA Applied to employees of contractors, not
subcontractors Regarding DOD contracts only Protected external reporting only Narrow definition of appropriate DOD official
New NDAA Protections (effective July 1, 2013) Apply to employees of both contractors and
subcontractors Regarding contracts with most federal agencies Now protects:
Internal complaints to management official with responsibility to investigate, discover or address misconduct
Protect participation in government investigation Provide for reinstatement, back pay, compensatory
damages and attorneys’ fees
National Defense Authorization Act
Protects disclosure of reasonable belief of: Gross mismanagement of federal contract/grant Gross waste of federal funds Abuse of authority concerning federal contract/grant Substantial and specific danger to public health/safety Violation of law/rule/regulation regarding federal
contract/grant (including the competition for same)
If disclosed to: Congress, IG of agency, GAO, federal employees with
oversight, law enforcement Company employee with responsibility to
investigate/address misconduct
Causation Standard: Contributing factor, not “but for” or “motivating” factor
NDAA Procedure and Remedies
Procedure Three-year statute of limitations Employee files with OIG OIG investigates Agency head issues decision Employee can file in federal district court if
no decision from OIG in 210 days Agency decision subject to review by
federal court of appeals Remedies: Reinstatement, back pay,
compensatory damages, attorneys’ fees and costs
Industries in the Line of Fire
• DOD and other traditional procurement contractors
• GSA schedule sales• Colleges and universities• Health care industry
• Medicare/Medicaid reimbursement• Research funding• Sales to VA
• Banking and financial industry• Retailers with sales to military and BX/PX• Subcontractors
Develop Effective Internal Policies
Update anti-retaliation policies and code of conduct to include additional and expanded claims Address additional categories of protected conduct Develop effective protocol for handling hotline calls and
complaints Confirm that confidentiality agreements, non-
disparagement provisions and settlement agreements do not restrict or impede reporting
Conduct frequent and effective management training Audit compliance
Incentivize internal complaints Effective and timely reporting mechanism Culture “driven from the top” that supports reporting Provide frequent updates to complainants Develop strong anti-retaliation policies and protections
Conduct Effective Internal Investigations
Develop effective procedures for investigating whistleblower claims Document and confirm the employee’s complaint Engage subject matter experts Break down the silos between HR, legal and
compliance Always consider and investigate self-help discovery,
including a forensic review of computers, devices and accounts
Be mindful of mandatory reporting obligations Ensure that treatment and results are consistent with
prior situations
Ensure objectivity in reviewing and managing the performance of whistleblowers who are current employees
Consider Mandatory Disclosure Obligations Throughout Process
Two separate considerations: Do the allegations of fraud of the whistleblower
trigger the duty to disclose Does the whistleblower’s own conduct or
performance trigger the obligations to disclose
Timing a key consideration Rules contemplate a reasonable investigation prior
to disclosure Swift disclosure can enhance client relationship and
deflate the impact of the whistleblower’s own filing or claim
Consider whether company has obligation to disclose whistleblower’s own misconduct
Drug Free Workplace Obligations
DFWA Coverage
Requires some contractors and all grantees to provide drug-free workplaces as a condition of receipt of contract or grant Generally applies to contractors if the value of a single contract
is $100,000 or more, other than acquisition of commercial goods Does not apply to subcontractors or subgrantees Only applies to performance inside of the United States
Requirement or indefinite quantity contracts covered if reasonably expected to exceed $100,000
Act requirements only apply to employees working on the covered grant or contract On payroll Works on any activity under the grant or contract (“direct” or
“indirect” charge) Temporary employees covered if meet criteria
Developing Issues – Protected Activity
Type of Contract/Grant Coverage
Students and recipients of Pell Grants Yes
Medicare third-party reimbursements to hospitals No
Hospitals that receive procurement contracts or grants
Yes
Banks and financial institutions selling US Treasury Bonds
No
Contractors and grantees performing work in federal facilities
Yes
Employees subject to drug testing requirements for security clearances
Yes, they co-exist
DFWA Requirements Vary
Requirements of FAR provisions adopted by agencies and departments vary For example, most do not require affirmative
provision of treatment or rehabilitation services Certain NASA contracts require contractors to
establish and maintain an appropriate rehabilitation program that requires, at minimum, identification and treatment of employees responsible for safety-sensitive, security or National security functions
Because Act applies on case-by-case basis, contractors must determine coverage and obligations imposed by each contract or grant (or for which they will be applying)
DFWA Requirements – Policy and Program
Publish and provide a policy to all covered employees that: States that the unlawful manufacture, distribution,
dispensation, possession or use of a controlled substance is prohibited in the workplace and
Identifies the actions that will be taken against employee who violate the policy
Requires establishment of drug-free awareness program to notify employees of: Dangers of drug abuse in the workplace Policy of maintaining a drug-free workplace Any available drug counseling, rehabilitation and
employee assistance programs The penalties that may be imposed on employees
for drug abuse violations
Notification Requirement
Each employee must be informed in writing of the policy and his or her responsibilities
Although contractors are not required to provide a notification each time a contract or grant is received, the program must be ongoing
Contractors are not required to obtain verification of receipt
Notification cannot be provided through collective bargaining representative or other agent
DFWA Requirements – Notification and Penalty
Also must notify employees that, as a condition of their employment on the contract or grant, the employee must: Abide by the terms of the policy statement; and Notify the employer, within five calendar days, if he or she is
convicted of a criminal drug violation in the workplace
Notify the contracting or granting agency within 10 days after receiving notice that a covered employee has been convicted of a criminal drug violation in the workplace
Impose a penalty on or requirement satisfactory participation in a drug abuse assistance or rehabilitation program by any employee who is convicted of reportable workplace drug conviction
Make an ongoing, good faith effort to maintain a drug-free workplace
What the DFWA Does NOT Require
Program not required to address alcohol and nonprescription drug abuse in programs
Does not require establishment of an EAP or special training for supervisors
Drug testing is not authorized or required
DFWA Enforcement
Compliance reviewed as part of the normal Federal contract and grant administration and auditing process
Federal agency head determines whether violation occurred
If determines that cause exists, action initiated and conducted in accordance with applicable FAR regulation and agency procedures
Contractors and grantees that violate the Act can receive one or more of the following penalties: Payments suspended Contract or grant suspended Barred from receiving additional contracts or grants
for up to five years
Restrictions on Arbitration Agreements and Programs
General Rules Regarding Mandatory Arbitration Agreements Federal Arbitration Act – arbitration encouraged Stolt-Nielsen S.A. v. AnimalFeeds Int'l Corp., 130 S. Ct. 1758
(2010) – an arbitration agreement that is silent regarding arbitrability of class actions implies class claims cannot be arbitrated
AT&T Mobility v. Concepcion, 131 S. Ct. 1740 (2011) – FAA preempts CA court decisions refusing to enforce class action waivers on grounds of unconscionability Iskanian v. CLS Transp. Los Angeles, LLC, Case No. S204032
(6/26/14), upholding class action waivers in employment arbitration agreements
CompuCredit Corp. v. Greenwood, 132 S. Ct. 665 (2012) – FAA requires courts to enforce arbitration agreements according to their terms even where underlying statute states that a plaintiff has the “right to sue”
American Express v. Italian Colors Restaurant, 133 S. Ct. 2304 (2013) – Arbitration agreements must be enforced as written; unavailability of class action procedure is not a barrier to enforcement of otherwise valid arbitration agreement; rejects “vindication of statutory rights” theory
Class Arbitration and Class Action Waivers
Summary from the Supreme Court Class arbitration is not consistent with the
underlying premises of the FAA Class action waivers are generally consistent with
the underlying premises of the FAA Class action waivers may be invalidated through
normally applicable contractual defenses (failure to agree, outside the scope, fraud) and state unconscionability standards so long as the standards are uniformly applicable, neutral in effect and consistent with federal arbitration policy
The same principles apply to federal statutory claims
None of this matters if an arbitrator has ruled that class actions were agreed upon, so long as there is some evidence of intent to agree
Class Arbitration and Class Action Waivers
Do these principles apply to Fair Labor Standards Act claims?
Yes: Sutherland v. Ernst & Young LLP, 726 F. 3d 290 (2d Cir. 2013) Question was whether Congress decreed that
collective actions are required for FLSA claims Plaintiffs claimed Section 216(b) collective actions
are a prescribed statutory procedure and thus evidence a congressional command not to allow class action waivers
Circuit concluded that while Congress authorized FLSA collective actions, it did not require them and did not foreclose an individual waiver of them
Second Circuit applied American Express (Supreme Court version) and rejected “effective vindication argument: Raniere v. Citigroup reaches the same conclusion
Other circuits have agreed: Richards v Ernst & Young, 2013 WL 4437601 (9th Cir. 2013)
Class Arbitration and Class Action Waivers
Do these principles apply to Title VII disparate treatment claims?
Second Circuit holds that they do in Parisi v. Goldman, Sachs & Co. 710 F. 3d 483
District Court (affirming Magistrate Judge Francis) had relied on effective vindication theory Judicial holdings in SDNY find that pattern or
practice claims may not be litigated in individual Title VII actions
Assuming an arbitrator would follow these cases, remitting a potential class plaintiff to individual arbitration would prevent her from litigating a pattern or practice claim
Therefore an arbitration agreement is not enforceable because its silent clause would bar class arbitration of a substantive right, the right to bring a pattern or practice claim
Class Arbitration and Class Action Waivers
Is a class action waiver lawful under the National Labor Relations Act?
In D.R. Horton, Inc., 357 N.L.R.B. No. 184 (2012), the employer required employees as a condition of employment to sign a Mutual Arbitration Agreement (“MAA”), which contained a class and collective action waiver
The Board found that employees have a § 7 right that forbids class action waivers, even where employees were not discharged or disciplined for filing a class action
Board held that the class action waiver in and of itself limited employees’ ability to engage in protected concerted activity, which included the filing of class or collective actions
But Fifth Circuit overruled in December 2013 holding that FAA required arbitration agreements to be enforced according to their terms
But – NLRB not bound by Fifth Circuit and continues to press its view (Leslie’s Poolmart and Sprouts Farmers Markets)
Franken Amendment
Provision of 2010 Department of Defense Appropriations Act that prohibits: The use of appropriated funds for any contract in
excess of $1 million If the contractor requires its employees to arbitrate:
All claims under Title VII of the Civil Rights Act of 1964 Tort claims related to or arising out of sexual assault or
harassment including assault and battery, intentional infliction of emotional distress, false imprisonment, or negligent hiring, supervision or retention
In the guidance published with the interim rule, DoD explained that the Franken Amendment does not affect the use or enforcement of mandatory arbitration agreements for non-covered claims
Franken Amendment Coverage
To be covered by the Amendment, a contractor must receive funds from the DoD
In final rule, DoD stated that the term “contractor” is to be construed narrowly Only refers to the specific entity that has the
contract Does not encompass a parent or subsidiary
corporation unless that parent or subsidiary is a party to the contract
The Amendment also does not apply to contracts for the acquisition of commercial items, including commercially available off-the-shelf items.
Franken Amendment Subcontractor Coverage
A “covered subcontractor” is any entity with subcontract valued in excess of $1 million, other than subcontracts for acquisition of commercial items
To receive funds from DoD, covered contractor must certify that it requires each “covered subcontractor” to agree not to enter into or enforce mandatory arbitration agreements requiring arbitration of covered claims by employees or independent contractors performing work relating to that subcontract Limited to those contracts placed by the contractor or
higher-tier subcontractors specifically for supplies or services for the performance of the contract
Does not apply to supplies or services a contractor or higher-tier subcontractor might purchase for other purposes
Franken Amendment Exceptions
There are three other exceptions to these restrictions on the use of mandatory arbitration. They do not apply to agreements that cannot be
enforced in this country The Secretary of Defense may waive these
restrictions on a case-by-case basis if the Secretary or the Deputy Secretary personally determines that the waiver is necessary to avoid harm to national security interest of the United States, and that the term of the contract or subcontract is no longer than necessary to avoid such harm
They do not apply to contracts for the acquisition of commercial items, including commercially available off-the-shelf items
Enforcement of Franken Amendment
There is very little case law on the applicability of the Amendment in general or on its ability to preclude arbitration.
In addition, the Amendment has not been used successfully to avoid arbitration.
In the only federal court decision addressing the Amendment, the court rejected the plaintiff’s argument that it precluded arbitration of his hostile work environment, race discrimination and retaliation claims. See Phifer v. Mich. Sporting Goods Distribs., Inc., 2010 U.S. Dist. LEXIS 93839 (W.D. Mich. July 28, 2010).
In a state case, a Texas appeals court ruled that employee’s personal injury claims, arising out of negligent hiring, supervision or retention were not covered by the amendment because they did not arise out of or relate to sexual assault or harassment. See In re ReadyOne Indus., 2012 Tex. App. LEXIS 10652 (Dec. 21, 2012).
Breaking News: July 31, 2014 Executive Order Fair Pay and Safe Workplaces New anti-arbitration provision applies to supply
and service contracts and subcontracts > $1 million
Excludes contracts for COTS Prohibits mandatory pre-dispute arbitration
agreements with respect to claims arising under Title VII of the Civil Rights Act of 1964 or any tort related to or arising out of sexual assault or harassment
Applies to employees and independent contractors
Doesn’t apply to arbitration provisions in CBAs Doesn’t apply to preexisting arbitration
agreements so long as such agreements aren’t subject to change by the employer or renegotiated
Breaking News: July 31, 2014 Executive Order Fair Pay and Safe Workplaces Contractors must include clause in covered
subcontracts Permits voluntary post-dispute agreements to
arbitrate DOL estimates 24,000 businesses employing
about 28 million workers impacted Will be implemented on new contracts in
stages, on a prioritized basis in 2016 following issuance of implementing regulations by the Federal Acquisition Regulation (FAR) Council and guidance by the U.S. Department of Labor (DOL)
No provision for waiver by agency like for Franken Amendment
Breaking News: July 31, 2014 Executive Order Fair Pay and Safe Workplaces Anti-arbitration rule is contrary to well-established
policy favoring arbitration Also inconsistent with employee interests
Median arbitration awards for all types of employment claims rose 60% from 2009-2010, from $208,000 to $241,119. Douglas Ashman, The Impact of Alternative Dispute Resolution in Employment Law, Purdue Univ. Coll. Of Tech. Masters Theses, Paper 56, p. 5 (2011)
In a study of 1,213 AAA cases from 2003-2007, the mean time for disposition in arbitration was 284.4 days for cases that settled, and 361.5 days for cases decided after a hearing, which is substantially shorter than the general two to two-and-a-half years that it takes to reach trial in federal and state courts. Alexander Colvin, An Empirical Study of Employment Arbitration Case Outcomes and Processes, Cornell Univ. ILR Sch., p. 12 (2011).
Breaking News: July 31, 2014 Executive Order Fair Pay and Safe Workplaces In a study of 1,213 AAA cases from 2003-2007, the mean arbitration
fees were $6,340 per case, $11,070 for cases disposed of by an award following a hearing, and in 97% of these cases the employer paid 100% of the arbitration fees beyond a small filing fee, pursuant to AAA procedures. Alexander Colvin, An Empirical Study of Employment Arbitration Case Outcomes and Processes, Cornell Univ. ILR Sch., p. 1, 13-14 (2011).
In a study of 1,213 AAA cases from 2003-2007, 82.5% of claimants had salaries under $100,000; 13.9% had salaries between $100,001 and $250,000; and 3.7% had salaries over $250,001. Alexander Colvin, An Empirical Study of Employment Arbitration Case Outcomes and Processes, Cornell Univ. ILR Sch., p. 1, 15 (2011).
Anecdotal reports from plaintiff attorneys state that potential claim amounts as much as $60,000 may be necessary to justify bringing a case forward in litigation. Alexander Colvin, An Empirical Study of Employment Arbitration Case Outcomes and Processes, Cornell Univ. ILR Sch., p. 15 (2011).
A 1995 article reported that 83% of works support arbitration over lawsuits or appealing to a federal agency. Jim Tyson, Workers Spurn Courts, Favor Arbitration, Christian Science Monitor (June 2, 1995) (citing “Worker Representation and Participation Survey: Wave Two”).
Compliance with FAR Provision Regarding Human Trafficking
FAR Subpart 22.17
The proposed rule prohibits federal contractors, contractor employees, subcontractors and subcontractor employees from engaging in any activities related to human trafficking, such as forced labor and prostitution
The following specific activities also prohibited:
Denying an employee access to his/her identity or immigration documents
Using misleading or fraudulent recruitment practices or charging recruitment fees
Providing or arranging housing that fails to meet the host country’s minimum housing and safety standards
Failing to provide return transportation or requiring payment for the cost of return transportation for certain employees
Compliance Plans and Certifications of Compliance
For contracts where a portion of the contract is performed overseas, a compliance plan and certification of compliance will be required
Will be required to certify:
Compliance plan has been implemented Neither the contractor, nor any of its agents,
subcontractors or their agents are engaged in human trafficking activities and
If abuses have been found, appropriate remedial and referral actions have been taken
Will impose strict reporting requirements Will be required to flowed down requirements
to subcontractors
Potential Remedies for a Violation of FAR subpart 22.18
Potential Remedies: Removal of employees involved in the allegations
from the contract Suspension of contract payments Withholding of award fees Refusal to exercise contract options Termination of contract or subcontract and/or Suspension or debarment
Must report violations to contracting officer and agency IG
In addition, the Government contracting officer must enter any violations in the Federal Awardee Performance and Integrity Information System (FAPIIS)
Wage and Hour Developments: Minimum Wage Increase for Contractor Employees
Wage and Hour Obligations of Contractors Generally
Recipients of government contracts, grants or financial aid are subject to additional wage, hour and benefits standards under: The Davis-Bacon Act (DBA), which requires payment
of prevailing wages and benefits to employees of contractors engaged in federal government construction projects
The McNamara-O'Hara Service Contract Act (SCA), which sets wage rates and other labor standards for employees of contractors furnishing services to the federal government
The Walsh-Healey Public Contracts Act (PCA), which requires payment of minimum wages and other labor standards by contractors providing materials and supplies to the federal government
The Wage and Hour Division of DOL administers and enforces these laws
Background of Executive Order 13658
Signed Executive Order February 12, 2014 Minimum wage $10.10/hour starting on
January 1, 2015 Will be increased each year based on the CPI Applies to contracts issued for solicitations
on or after January 1, 2015 Covered contracts must include a clause
increasing the minimum wage Contractors must incorporate that clause into
lower-tier subcontracts Proposed Final Rules issued on June 17, 2014 FAR provision will be issued
Proposed Final Rules – Contracts Covered
Will apply to: Procurement contracts for construction covered by
the DBA Service contracts exceeding $2,500 covered by the
SCA Concessions contracts with the federal government,
including contracts excluded from SCA coverage by regulation
Contracts to provide services to federal employees, their dependents or the general public on federal property or lands
Excludes the following from coverage: grants, procurement contracts for construction not subject to DBA, certain contracts with Indian Tribes, and service contracts that are exempt from SCA
Proposed Final Rules – Employees Covered
Employees entitled to at least the specified minimum wage for: All hours spend working on a covered contract All time spent providing support work necessary for
covered contracts Employees are entitled to coverage under the EO
even if they are not covered by the DBA or SCA Special rules apply to tipped employees
Must receive a minimum hourly wage of $4.90/hour, plus the amount earned in tips
If the combination does not total at least $10.10/hour, employer must make up the balance
Each year, the wage will increase 95 cents until the tipped minimum wage equals 70 percent of the wage for non-tipped employees
Additional Counseling and Litigation Issues
Enforcement of Restrictive Covenants
Restrictions on use and disclosure of trade secrets and other confidential information of company and government customers critical in government contracting context
In addition to traditional NDAs, many contractors use post-employment restrictions, such as non-competes and non-solicitation provisions
Contractors efforts to enforce these restrictions have faced some challenges: Does the contractor have a sufficient ownership interest in the
protected information/data to support the restrictions? Can employees “prepare to compete” by allowing their resume
to be submitted on a blind basis in connection with a competing bid?
Does the government’s interests in having experienced workers on their contracts trump the employer’s interests, particularly when SCA contracts are involved?
Increasing the Likelihood of Enforcement
Consider implications of forum selection and choice of law provisions
Narrowly tailor the restrictions to the interests sought to be protected Traditional restrictions:
Time period Geography Definition of competitor or competitive activity
Additional restrictions to consider: Identifying specific conduct prohibited (i.e., submission
of resume) Tie to specific contracts and customer contacts
Tie restrictions to confidential and proprietary information of the contractor (as opposed to the customer)
Litigation Procedures and Defenses that MAY be Available to Contractors Government Contractor Defense – Contractor
followed contract specifications and warned government
Defense Base Act – Exclusive remedy for federal contractor employees who suffer injury oversees while working on contract
Derivative Sovereign Immunity – Contractor had discretion to act in area that required balancing of federal public policy considerations
Immunity for Compelled Disclosure – Contractor required to inform government of suspected activity or respond to government inquiry
Government Actor Defense – If government supervisor made challenged employment action, contractor employee may be required to pursue EEO remedies through MSPB procedures
Additional Compliance Obligations Imposed by July 31, 2014 Executive Order
General Requirements
Applies a wide range of new requirements on federal contractors
Most provisions apply to contracts over $500,000
Will be implemented throughout 2016 Department of Labor will issue regulations
implementing the Order
Mandatory Disclosure of Violations
Mandatory disclosure of labor law violations
As part of a bid, contractor must disclose “administrative merits determination, arbitral award or decision, or civil judgment” of the following: FLSA, OSHA NLRA, Davis-Bacon Act, Service
Contract Act, Section 503 of Rehabilitation Act, VEVRRA, FMLA, Title VII of Civil Rights Act, Executive Orders 11246 (equal employment opportunity) and 13658 (minimum wage) and Migrant and Seasonal Agricultural Worker Protection Act
“Equivalent State laws” to the list above
Mandatory Disclosure of Violations
Agencies will use disclosures to determine whether contractor acts with integrity and complies with business ethics to either obtain a federal contract or to continue operating under a federal contract
In addition: Must update disclosures every six months Must obtain similar disclosures from
subcontractors
Agencies must designate a senior official to subject the worst violators to penalties, including disbarment
Pay Disclosure Obligations
Contractors must provide workers with specific information on their paycheck, including hours worked, overtime hours worked, total pay, and any additions or deductions made to employees’ pay
If a contractor is treating a worker as an independent contractor, the contractor must inform the individual of their status as an independent contractor
Learning from the Legacy, Focused on the Future
Proskauer Blog:Government Contractor Compliance &
Regulatory Update
Proskauer’s Government Contractor Compliance & Regulatory Update Blog – Track the Developments
Government contractors and subcontractors face unique compliance, employment, and contractual issues when managing government contracts. Follow the near-daily
developments in the government contract compliance arena, with a particular focus on updates involving the OFCCP and related agencies and departments. For the latest
insights, check out our blog – Proskauer’s Government Contractor Compliance & Regulatory Update at:
http://www.governmentcontractorcomplianceupdate.com/