New Rule for Government Contractors: Executive Compensation And Subcontracts Reporting
Bridget Pulivarti, SPHR, Practice Lead, Government Contracting & Recruiting

Are you aware of the new ruling requiring contractors to report the names and compensation of their five (5) highest paid executives and those of their subcontractors? This information will be publicly available on www.usaspending.gov and the Central Contractor Registration website www.bpn.gov/ccr/.

The interim rule went into effect July 8, 2010 and applies to all federal contracts, including commercial item contracts. The rule requires government contractors to identify first tier subcontract awards of $25,000 or more and to report annually:

• Names and total annual compensation of their five (5) highest paid executives; and
• Names and total annual compensation of their first tier subcontractors' five (5) highest paid executives.

Reporting total executive compensation is required if the contractor/subcontractor meets all of the following criteria:

• Annual gross income is $300,000 or greater in the preceding fiscal year;
• 80% or greater of annual gross revenues are from federal contracts, loans, grants, and cooperative agreements;
• $25 million or greater of annual gross revenue from federal contracts, loans, grants, and cooperative agreements; and
• Executive compensation information not reported to Securities and Exchange Commission.

Total compensation is defined as cash and noncash including salary, bonuses, awards of stock, stock options, stock appreciation rights, earnings for services under non-equity incentive plans, changes in pension value, above market earnings on deferred compensation that is not tax qualified, and any other compensation earned by an executive during the contractor's or subcontractor's preceding fiscal year.

The following are exempt from the rule:

• Contracts valued under $25,000;
• Contractors/subcontractors whose annual gross income is under $300,000;
• Individuals with contracts; and
• Classified contracts.

These new reporting requirements will be phased in over time as follows:

• July 8, 2010 through September 30, 2010 - all newly awarded subcontracts must be reported if the prime contract award amount is $20 million or greater;
• October 1, 2010 through February 28, 2011 - all newly awarded subcontracts must be reported if the prime contract award amount is $550,000 or greater; and
• March 1, 2011 - all newly awarded subcontracts must be reported if the prime contract award is $25,000 or greater.

To learn more about these changes for government contractors, click on this link: Executive Compensation Reporting or feel free to contact Bridget Pulivarti directly at 703-860-3882 x118.

It's that time of year again!
EEO-1 and Vet 100/100A reports due September 30, 2010
Bridget Pulivarti, SPHR, Practice Lead, Government Contracting & Recruiting

The end of September brings with it the annual filing deadline for two important government-required reports that apply to many employers - the EEO-1 and the Vets 100/100A reports.

EEO-1 Report

Private sector employers who employ 100 or more employees and government contractors who employ 50 or more employees are required to file an annual EEO-1 report with the U.S. Equal Employment Opportunity Commission's EEO-1 Joint Reporting Committee. For instructions on filing, please click the following link: EEO-1 Report

Vets 100/100A Report

Under VEVRAA (Vietnam Era Veterans' Readjustment Act of 1972) and as amended by the Jobs for Veterans Act, regulations require government contractors to file an annual Vets 100/100A report with the Veterans' Employment and Training Service of the U.S. Department of Labor as follows:

• Government contractors with contracts and/or subcontracts in the amount of $25,000 or greater prior to December 1, 2003 that have not been modified on or after December 1, 2003 should file a Vets 100 report.
• Government contractors with contracts and/or subcontracts in the amount of $100,000 or greater on or after December 1, 2003 should file a Vets 100A report.

For additional filing information, please click on the following link: DOL Federal Contractor Program

Cups Full of Hope

Helios HR is honored to be a sponsor of Cups Full of Hope to be held on Wednesday, September 15, 2010. The event is a thought-provoking art exhibition to raise awareness about breast cancer. This fundraising event will benefit a local non-profit, Tigerlily Foundation, which helps support women under the age of 40 living with breast cancer.

Visit Cups Full of Hope for registration information and other details.

The Essential Performance Review Handbook
by Sharon Armstrong

Although performance reviews are actually less popular than a trip to the dentist for most supervisors (an actual study!), the good news is "The Essential Performance Review Handbook" takes the pain out of the process. A quick and handy resource for any manager or HR professional, this book offers 224 pages of advice on how to make the process productive, painless, and effective.