Comment on FAR Pay Equity Rulemaking

ARTBA filed comments on the Department of Defense (DOD), General Services Administration (GSA), National Aeronautics and Space Administration (NASA), and the Office of Federal Procurement Policy’s proposed rule regarding pay equity in government contracting. ARTBA recommended that the agencies revise their proposal to provide further clarity to the rule. ARTBA stressed that the agencies ensure the rule’s requirements are not overly expansive and do not hinder a contractor’s capacity to attract and retain talent.

Key points raised in the comment include:

1. The proposed rule raises ambiguities and uncertainties for contractors. To remedy this, ARTBA suggested that the agencies describe what is meant by work performed ‘in connection with’ a federal contract, as well as the term ‘certain positions’ included within the rule.
2. ARTBA stressed that federal contracting hiring practices should not impede market competition and employee development.