As discussed during the 2018 ILG National Conference, Acting Director Craig Leen has released a Directive formalizing OFCCP’s plans to start initiating focused reviews.  Acting Director Leen, simultaneously released a Directive addressing religious discrimination – a topic not broadly (or otherwise) discussed during the Agency’s recent public engagements.

The stated purpose of Directive 2018-03: Executive Order 11246 Sec 204(c), religious exemption is “to incorporate recent developments in the law regarding religion-exercising organizations and individuals.

The stated purpose of Directive 2018-04: Focused reviews of contractor compliance with Executive Order 11246 (E.O.), as amended; Section 503 of the Rehabilitation Act of 1973 (Section 503), as amended; and Vietnam Era Veterans’ Readjustment Assistance Act of 1974 (VEVRAA), as amended is “to direct that a portion of future scheduling lists include focused reviews as to each of three authorities that the Office of Federal Contract Compliance Programs enforces.

We are in the process of reviewing each directive and will provide our thoughts and insights on both the Directive 2018-03 and Directive 2018-04 soon.