Executive Order 13706 establishes paid Sick Leave for Federal Contractors. Effective January 1, 2017, the EO requires certain employers that contract with the Federal Government to provide their employees with up to seven days of paid sick leave annually including for family care and absences resulting from domestic violence, sexual assault, and stalking.

This is not a prevailing wage law, but is always applicable in prevailing wage situations.

The Executive Order covers procurement contracts for construction covered by the Davis Bacon Act (DBA), Service contracts covered by the McNamara-O’Hara Service Contract Act (SCA), concessions contracts, including any concessions contracts excluded from the SCA by the DOL regulations at 29 CFR 4.133(b), and contracts in connection with Federal property or lands and related to offering services for Federal employees, their dependents, or the general public.

The EO is specific regarding minimum accrual rates, limits on annual maximums, end of year steps, and treatment of rehires. It cannot count as a required fringe (Davis Bacon), and is not Holiday or Vacation (Service Contract Act).

Steps for compliance require consistency and accuracy. There are things to look out for, along with some “nice to knows”, when incorporating Sick Time Tracking into an Employee Benefit Plan.