[il-talk] Fwd: FW: Comments Needed to Ensure that Executive Order Doesn’t Exempt 14c Entities from Paying New Minimum Wage

[Rose Sloan]

Fellow Federationists:



As you know, President Obama has issued an executive order that raises the
minimum wage for federally contracted service providers—including those
employees who are being paid under Section 14(c) of the Fair Labor
Standards Act. The Notice of Proposed Rule Making (NPRM), the
interpretation of this executive order, has been released by the Department
of Labor (DOL). They will be accepting comments until July 28.



It is important that we express our support for the Executive Order. We’ve
heard that some people might urge DOL to exempt some organizations that use
14(c) certificates, and we want to outnumber that kind of feedback.



I encourage each of you to send me comments that you would like submitted.
For your convenience, I have provided a sample letter. Please feel free to
use some of this language in the comments you wish to be sent, specifically
the part about AbilityOne’s Procurement List (PL) contracts.



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Ms. Mary Ziegler

Director of the Division of Regulations, Legislation, and Interpretation

U.S. Department of Labor, Wage and Hour Division

200 Constitution Avenue, N.W., Room S-3510

Washington, DC 20210



Re:  Notice of Proposed Rulemaking: Establishing a Minimum Wage for
Contractors RIN: 1235-AA10



Dear Ms. Ziegler:



I fully support the Notice of Proposed Rulemaking (NPRM) of the executive
order “Establishing a Minimum Wage for Contractors.” I sincerely thank the
president and the Department of Labor for formulating this executive order
as I feel that it is an important first step toward ensuring equality in
the workplace for American workers with disabilities.



I applaud the Department of Labor for including people with disabilities
whose wages are calculated under Section 14(c) of the Fair Labor Standards
Act in the definition of “worker.” People with disabilities are indeed
workers, and with the proper training and support can be just as productive
as non-disabled peers. I believe that the biggest obstacle that people with
disabilities face to equal employment is low expectations. When we are held
to the same standards as our non-disabled peers we will rise to the
occasion and perform to the level that is expected of us. We may need
accommodations to do this, but laws such as the Americans with Disabilities
Act and Rehabilitation Act legally grant us these reasonable
accommodations.



Executive Order 13658 states that any new or renewed federal contract that
provides services starting on or after January 1, 2015 will be required to
pay all employees at least $10.10 an hour. I hope that the contracts placed
on the AbilityOne Procurement List (PL) will not be exempted from this wage
floor requirement. Although these contracts, once placed on the PL, are
exempted from external competition, they are subject to renewal and
renegotiation as any other contract. Most importantly, these contracts
employ workers with disabilities that (if the contracts are exempted) would
not benefit from the increase wage provided through the executive order as
intended.



I believe that excluding people with disabilities from the protection of
the minimum wage is discriminatory, and the NPRM of the executive order
“Establishing a Minimum Wage for Contractors” takes an important first step
in eliminating the practice of paying people with disabilities subminimum
wages. I hope that the Department of Labor and the president will continue
to work with stakeholders to ensure that Americans with disabilities are
guaranteed the protections in the workplace that we deserve. Thank you for
considering my feedback.



Sincerely,



_______________



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Please send your comments to me at rsloan at nfb.org no later than 8 PM on
Sunday, July 27th. Thanks for all that you do, and I look forward to
reading your comments!



Yours in the fight for fair wages,



Rose







*Rose Sloan*

Government Affairs Specialist



*National Federation of the Blind *

200 East Wells Street

Baltimore, MD 21230

Phone: (410) 659-9314, extension 2441

Email: rsloan at nfb.org



“Eliminating Subminimum Wages for People with Disabilities”

http://www.nfb.org/fair-wages



The National Federation of the Blind knows that blindness is not the
characteristic that defines you or your future. Every day we raise the
expectations of blind people, because low expectations create obstacles
between blind people and our dreams. You can live the life you want;
blindness is not what holds you back.



To make a donation to the National Federation of the Blind Imagination
Fund, please visit www.nfb.org/ImaginingOurFuture.