The third of the three Directives OFCCP issued last Friday, Directive 2018-06 “Contractor Recognition Program” announces a program by which OFCCP will recognize contractors with “high-quality and high-performing compliance programs and initiatives.” Recognition is one of the four themes Acting Director Leen has spoken about recently and such programs are not a new concept in the Agency – some of you may recall OFCCP’s previous EVE Award program.   The Agency’s new Directive, however, describes a program having much more potential than a simple recognition program.

While the Directive is short on specific details for the program, it shows OFCCP is looking for creative and more effective ways to encourage voluntary compliance and further the core principles of affirmative action.  In furtherance of the Agency’s efforts to efficiently and effectively “expand its compliance reach,” the heart of the Directive is the idea that contractors can, and should, learn from one another regarding effective AAP efforts.  The program would advance OFCCP’s compliance assistance efforts by identifying contractors with “innovative programs” driving “demonstrable results” that “could be taught or incorporated into contractor peer mentoring programs.”

OFCCP believes contractors would be supportive of a compliance assistance model that includes a peer-to-peer mentoring type component because OFCCP found contractor believe

other businesses best understand their compliance barriers and challenges.

The program will not simply recognize compliant contractors “but would be for contractors that are innovative thought leaders among their peers for achieving diverse and inclusive workplaces.”  OFCCP would take the first step of identifying and approving “implementable best or model contractor practices,” and presumably establish a foundation and framework for a mentoring program through which contractors could expand and build upon the successes of their peers.

Collaboration is also central to this proposed program in another aspect.  Rather than working alone, OFCCP promises to work directly with other federal entities, such as “the Women’s Bureau, the Office of Disability Employment Policy, and other Department of Labor components as appropriate.”

OFCCP has not provided a timeline for the development of this program so stayed tuned to this page for further updates as OFCCP makes them available.

Tags: Acting Director Craig Leen, Contractor Recognition Program, Directive 2018-06, OFCCP, Office of Federal Contract Compliace Programs, Recognition programs
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Photo of Laura A. Mitchell Laura A. Mitchell

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with…

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with employers to build programs that benefit employees and create a stable, high-functioning workplace. Understanding that an inclusive, values-based culture provides a crucial competitive advantage in the modern workplace, Laura enjoys counseling companies on the development of proactive and equitable pay and diversity practices.

In Laura’s version of the reimagined workplace, attention to human capital issues, especially DEI and pay equity, would be the rule rather than the exception nationwide and she works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize this vision for her clients’ ongoing success. She helps clients understand all issues across the spectrum of their journey, helping to establish regular analyses as well as counseling organizations on implementation and compliance obligations, where applicable. Committed to putting her clients’ organizational goals first and foremost, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication.

Laura also represents companies in OFCCP matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming from OFCCP regulations. She personally oversees the development of hundreds of Affirmative Action Plans for clients each year and is intimately involved in the defense of OFCCP audits. Her approach to compliance is one of facilitation and conciliation while simultaneously advocating in the best interests of her clients.

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