CWC has filed comments with the White House Office of
Federal Procurement Policy and the Federal Acquisition Regulatory (FAR)
Council in response to the proposed rule
on Pay Equity and Transparency in Federal Contracting. The proposal would
require contractors to disclose salary and benefits in advertisements for jobs
to be performed under a covered contract, prohibit contractors from using compensation
history in making employment decisions, and mandate an employee rights notice.
CWC’s comments do not criticize the proposed rule’s major
elements but instead address practical questions and make recommendations for
reducing the potential compliance burden. For example, CWC recommended that the
rule allow contractors to consider the compensation history of applicants who
disclosed their prior pay on their own initiative and of their current workers who
are being considered for transfers or promotions. Furthermore, CWC urged that
contractors who act in good faith be given significant flexibility when
identifying the specific agency that awarded the contract or issued
the solicitation on which an applicant would primarily work.