Yesterday’s Advisor talked about general posting requirements. Today we’ll look at special posting requirements for federal contractors, again courtesy of HR.BLR.com®. Plus, we’ll take a look at an HR audit program to help you check your posting process—and just about everything else you do.
Federal contractors have posting requirements beyond those of other employers. (Go here for yesterday’s discussion of general HR posting requirements.) Here’s what contractors need to know:
Davis-Bacon Act
Who must post: Federal government contractors and subcontractors with federal contracts of $2,000 or more for the construction, alteration, or repair of a public building or public works, or buildings financed by federal funds, federal guarantee, or federal pledge.
What must be posted: A notice explaining the rights of employees to a minimum wage, overtime, and apprentice rates of pay.
Executive Order 11246, Rehabilitation Act of 1973, and Vietnam Era Veterans Readjustment Assistance Act (VEVRAA)
Each act has a posting requirement that is met by displaying the consolidated EEO poster.
Jobs for Veterans Act (JVA), which amended VEVRAA
Who must post: Government contractors with contracts of $50,000 or more entered into before December 1, 2003, and contracts of $100,000 or more entered into after December 1, 2003.
What must be posted: Under the JVA, contractors must post job openings with the appropriate employment service delivery system. All job openings must be posted, except executive and top management positions, positions that will be filled internally, and positions lasting 3 days or less.
Using the “hope” system? (We “hope” we’re doing it right.) Check out every facet of your HR program with HR Audit Checklists.
Contractors can satisfy the posting requirements by listing job openings with the state workforce agency job bank for the state where the job opening occurs or with the appropriate local employment service delivery system where the opening occurs. Listing must be done simultaneously with the contractor’s use of any other recruitment efforts.
Contractors can list employment openings by submitting them via mail, fax, e-mail, or other electronic posting, and may enlist the services of third parties.
There are special rules for government contracts and subcontracts of $25,000 or more: Contractors must list employment openings with the appropriate local employment service office where the opening occurs. Listing with the state workforce agency job bank in the state in which the opening occurs will also satisfy the listing requirement.
Executive Order Requiring Notification of Rights Under the NLRA
On January 30, 2009, President Obama revoked Executive Order 13201 and issued a new Executive Order requiring covered contractors and subcontractors to post a broader notice of employee rights under the National Labor Relations Act (NLRA), including the right to bargain collectively and to join a union. The required poster should be available soon.
Walsh-Healy Act (Public Contracts Act)
Who must post: Federal government contractors and subcontractors with 50 or more employees and federal contracts of $10,000 or more.
What must be posted: “Notice to all Employees Working on Government Contracts” explaining the rights of employees to a minimum wage, overtime, and fringe benefits, as well as workplace safety rules. The poster must be displayed where employees will see it as they arrive for and leave from work.
Contractor or not, posters can be a hassle. But they’re not even close to being your biggest hassle, right?
How can you ever be sure that posters—and about four dozen other HR tasks—are being done right?
Fortunately, there’s a simple tool for making sure you are in compliance with posting laws and all the other laws and regulations in HR land—the HR audit. It’s the only surefire way to identify problems early, and correct them before they turn into expensive lawsuits.
Experts recommend an annual audit but, if you are concerned, perhaps next week would be better? In either case, to do a good audit, you need audit checklists, and there’s good news: BLR’s editors have already written them—for all of the most challenging areas of HR.
Don’t “just do it” … do it right. HR Audit Checklists assures that you know how. Try the program at no cost or risk. Find out more.
Why Checklists?
Why are checklists so great? Because they’re completely impersonal, and they force you to jump through all the necessary hoops, one by one. They also ensure consistency in how operations are conducted. And that’s vital in HR, where it’s all too easy to land in court if you discriminate in how you treat one employee over another.
The program our editors recommend is BLR’s HR Audit Checklists.
Just as an example of how it compels thoroughness, it contains not one but seven checklists relating to recordkeeping and digital information management. One lists 34 types of data and also covers confidentiality, emergency planning, efficiency, compliance with laws, and safety. You’d likely never think of all those possible trouble areas without a checklist, but with it, just scan down the list and you instantly see where you might get tripped up.
In fact, housed in the HR Audit Checklists binder are dozens of extensive lists organized into reproducible packets, for easy distribution to line managers and supervisors. There’s a separate packet for each of the following areas:
- HR Administration (including communications, handbook content, and recordkeeping)
- Health and Safety (including OSHA responsibilities)
- Benefits and Leave (including health cost containment, COBRA, FMLA, workers’ compensation, and several areas of leave)
- Compensation (payroll and the Fair Labor Standards Act)
- Staffing and Training (incorporating Equal Employment Opportunity in recruiting and hiring, including immigration issues)
- Performance and Termination (appraisals, discipline, and termination
HR Audit Checklists is available for a no-cost, no-risk evaluation in your office for up to 30 days. Visit here and we’ll be happy to arrange it.
Other Recent Articles on Management
Mid-Year Poster Check: Are You in Compliance?
HR as Strategic Partner? Restructure, Rebrand
Want a Seat at ‘the Table’? Think Strategically
The Other Wellness: Alcohol, Drugs, Backs, Sleep, and Stress