In July, we alerted government contractors and subcontractors to the Department of Labor’s (DoL) Proposed Rule to implement Executive Order (EO) 13658, which raises the minimum wage for covered employees working directly on, or contributing to, covered federal contracts and subcontracts to $10.10 per hour.

As we stated in our initial client alert, EO 13658 requires, beginning January 1, 2015, that covered federal contracts and subcontracts contain a clause specifying that the minimum wage to be paid to covered workers must be at least $10.10 per hour. As discussed further below, the EO and implementing regulations do not require contractors to pay all employees the minimum wage.