1. Home
  2. |Insights
  3. |Wait, What? Administration Now Designates “Fair Pay and Safe Workplaces” as Not Economically Significant

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

Client Alert | 1 min read | 05.10.16

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 so as 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 before sending them to the FAR Secretariat for publication, discussed here) now lists the new rules as not “Economically Significant.” That determination allows the administration to avoid the requirements under EO 12866 to provide a more detailed assessment of the likely benefits and costs of the regulatory action, but it reverses the administration’s prior designation of these burdensome new compliance and reporting obligations, and it seems at odds with the designation of other rules, such as “Serving Sizes of Foods That Can Reasonably Be Consumed at One Eating Occasion” and “Energy Efficiency Standards for Residential Dehumidifiers,” as Economically Significant.

Insights

Client Alert | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....