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Human Resources

Human Resources for GSA Contractors

GSA Schedule contractors must adhere to a number of complex laws and regulations that affect their Human Resource operations and employees. There are various laws that make it illegal for contractors and subcontractors doing business with the federal government to discriminate against applicants or employees because of race, color, religion, sex, sexual orientation, gender identity, national origin, disability, or status as a protected veteran. Among these requirements, GSA Schedule contractors must file certain reports and maintain records consistent with Executive Order 11246, Section 503 of the Rehabilitation Act (Section 503), and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA).  Some of these HR requirements are outlined below, while others may be referenced in resultant contracts and task orders.


A presidential Executive Order and subsequent Federal Acquisition Regulation (FAR) rule requires federal contractors to use E-Verify to electronically verify the employment eligibility of employees working under covered federal contracts by matching information provided by employees on the Form I-9 against records available to the Social Security Administration and the Department of Homeland Security. GSA Schedule contractors should also display the E‑Verify Participation and Right to Work posters in a prominent location where both prospective and existing employees can see it.

Equal Opportunity

A GSA Schedule contractor, with at least 50 full-time employees and a federal contract (or subcontract) worth more than $50,000, is required to file the annual Equal Employment Opportunity (EEO-1) Survey. Contractors and subcontractors are also required to display the Equal Opportunity Clause poster in a conspicuous place available to employees and applicants for employment.

Affirmative Action Program

A GSA Schedule contractor, with at least 50 full-time employees and a federal contract (or subcontract) worth more than $50,000, must maintain an Affirmative Action Program (AAP) for each of its establishments and include all employees.


A GSA Schedule contractor must report annually to the Department of Labor the number of employees in its workforce who belong to the categories of veterans and the number of those employees who were hired during the period covered by the report. Each contractor or subcontractor must provide the required information on veterans’ employment by filing the annual Veterans’ Employment Report VETS-4212.

Service Contract Act

The Service Contract Act (SCA) requires GSA Schedule contractors who are performing certain services within the US to pay a service employee in various classes no less than the wage rates and fringe benefits found prevailing in the locality, or the rates (including prospective increases) contained in a predecessor contractor’s collective bargaining agreement. A “service employee” is a worker that performs services but is not an executive, administrative, or professional employee under the Fair Labor Standards Act. Contractors and subcontractors must notify employees performing SCA contract work of the compensation due them under the applicable SCA wage determination in the covered contract, and must display the “Notice to Employees Working on Government Contracts” Department of Labor Publication conspicuous place available to employees at the worksite. State and local wage and hour laws may also apply to workers concurrent with compensation requirements under SCA.

Business Ethics and Conduct

All federal contractors must conduct themselves with the highest degree of integrity and honesty.  GSA Schedule contractors are required to exercise due diligence to prevent and detect criminal conduct and promote an organizational culture that encourages ethical conduct and a commitment to compliance with the law. As such, contractors are required to have a written code of business ethics and conduct, specific to federal contracting, and make a copy of the code available to each employee engaged in performance of a federal government contract. In addition, GSA Schedule contractors must self-disclose credible evidence of fraud and violations of certain criminal laws and the False Claims Act.