Florida Minimum Wage
Employers in both the public and private sectors are required to pay the minimum wage regardless of the size of the company or the number of employees. Under the amendment, the minimum wage will increase by $1.00 per hour on every September 30 through 2026. Beginning in 2027, the minimum wage will be adjusted annually for inflation, as it has been since 2004. Below is the scheduled for the increases:
• $11.00 on September 30, 2022
• $12.00 on September 30, 2023
• $13.00 on September 30, 2024
• $14.00 on September 30, 2025
• $15.00 on September 30, 2026
It should also be noted that beginning on September 30, 2021, that the minimum wage for tipped employees will be increased to $6.98 per hour. Additionally, the minimum wage for tipped employees will be increased annually by $1.00 on September 30 through 2026. The wage for tipped employees will increase as follows:
• $7.98 on September 30, 2022
• $8.98 on September 30, 2023
• $9.98 on September 30, 2024
• $10.98 on September 30, 2025
• $11.98 on September 30, 2026
Federal Contractors Minimum Wage
On April 27, 2021, President Biden issued an Executive Order raising the minimum wage for federal contractors from $10.95 per hour to $15.00 per hour, effective January 30, 2022.
This new minimum wage will be “phased in” on January 30, 2022, starting with new contracts issued on or after this date, and also applying to any existing contract that is subsequently extended or renewed on or after January 30, 2022. Moreover, the President’s Executive Order “strongly encourages”--but does not require--that contracts entered into by federal agencies before January 30, 2022, observe the new $15.00 minimum wage.
Only when the contract is extended or renewed after January 30, 2022, will the $15.00 minimum wage requirement take effect for contracts entered into prior to the effective date. If an option in a contract entered into prior to January 30, 2022, is exercised after this date, then the $15.00 minimum wage requirement will also take effect.
Beginning January 1, 2023 (and annually thereafter), the minimum wage for federal contractors will be adjusted for inflation, and the new minimum wage can never be lower than the one that preceded it. Any adjustments will be published by the Secretary of Labor at least 90 days before any new minimum wage is to take effect.
In addition to preparing for internal wage adjustments, another area that contractors may want to start preparing for early is in their diligence of subcontractors. Contractors will be required to incorporate the higher minimum wage into lower-tier subcontracts, so this requirement will need to be factored into subcontractor selection processes, particularly where the process includes an evaluation of subcontractor pricing for work to be performed in future years.
The Secretary of Labor will issue additional guidance and regulations by November 24, 2021. These regulations will address the implementation and additional requirements of the President’s Executive Order.
If you have any questions on the impact of this proposed legislation on the ERTC, please contact RVG & Company at 954. 233.1767.
2020 RVG & Company
