President Obama’s OFCCP 2015 fiscal year budget proposal remains true to OFCCP’s recent increased enforcement objectives – including the Agency’s increased focused on pay equity enforcement.
The budget seeks an additional $1.1 million over the 2014 budget to be spread across the following areas:
- 10 additional full-time employee equivalents (for a total 710) “to strengthen enforcement efforts to combat pay discrimination…” If you remember, OFCCP’s fall 2013 Regulatory Agenda had set January 2014 for a revised Compensation Data Collection Tool;
- Increased monitoring of potential discrimination in construction. This is also consistent with OFCCP’s Regulatory Agenda which sets an April 2014 timetable for proposed new construction rules;
- Monitoring of contractor efforts to recruit, hire and retain veterans and the disabled in the wake of the March 24, 2014 effective date of the new Regulations. To this end, the Budget documents state OFCCP will “ensure that contractors and subcontractors are provided linkages to recruitment sources for hiring and advancement of minorities, women, protected veterans, and individuals with disabilities.” In connection with revising the veterans and disability regulations, OFCCP has recently updated these resources – which can be found here and here;
- Audits – OFCCP projects 4,290 audits in 2015, up from 4,110 in 2014, “with a focus on both supply and service and construction reviews.”
The President’s support (and proposed funding) of OFCCP’s continued aggressive enforcement agenda means now, more than ever, employers, including construction contractors, need to make sure their affirmative action programs are in compliance and that they are thinking proactively about pay and hiring issues.