Federal Contractors and New Sick Leave Requirements

Updated: Feb 10, 2020

While federal contractors have been subject to paid sick leave requirements since 2017, as state and local sick leave laws are becoming more prevalent and the trend seems to be growing, a review of policies in this area should be conducted regularly to identify and mitigate risk.

A key thing to look for when performing a review or a compliance check in this area is that most state and local laws are often broader in application than the requirements established by the Department of Labor’s Final Rule for contractor sick leave.

While a lot of the basic requirement appear to be consistent, a lot more employees fall under the coverage of state and local laws, as their scope is not limited to certain contracts or inclusion of specific clauses in solicitations.

A compliance check should be thorough and recognize that while there are many similarities between the federal, state and local laws, there are also critical differences. A compliance matrix is a great way to keep track of requirements. The review checklist, or matrix should be comprehensive, and at a minimum contain the following areas:

  • Covered Employees

  • Benefit Entitlement

  • Required Accrual Schedule

  • Maximum accruals/caps

  • Carryover

  • Permitted uses

  • PTO instead of Sick Leave

  • Payout upon Termination

While this is subject to change, here is a listing of states that currently require sick leave for private employers:

  • District of Columbia

  • Connecticut

  • California

  • Massachusets

  • Oregon

  • Vermont

  • Arizona

  • Washington

  • Rhode Island

  • Maryland

It is critical to check local jurisdictions as there are counties and cities that are taking action in this area.

What’s next? Start with a review of where you stand. Look at your existing policies, compare them to applicable requirements. Identify gaps and put a plan in place to fill in the gaps. Institute procedures to monitor for continued compliance.

A better balance is a site that is great to get an overview of requirements.


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