Following the tone of the preceding days, the 2018 ILG National Conference closed Friday morning with a friendly conversation between Acting Director Craig Leen and NILG Chair Paul McGovern. The two discussed several of the themes and OFCCP initiatives addressed during the conference:
- Transparency, certainty and the Rule of Law
- The Agency’s audit scheduling process
- Directive 307 and pay discrimination
- OFCCP’s Pre-Determination Notice Directive
- The “Contractor Bill of Rights“, which Leen explained was more of a “statement of principles”
- The importance of Section 503 diversity and inclusion programs
Contractor Certification
Acting Director Leen also discussed a new topic – the Agency’s work to develop a contractor verification or certification process. Leen discussed the current General Services Administration’s (GSA’s) certification process which occurs within the System for Award Management (SAM) registration system. He described how the simple “check-the-box” certification question likely does not capture accurately who is in compliance with their affirmative action obligations. Leen recognized those in attendance likely already prepare affirmative action plans but raised concern about the many that do not because of a low risk of audit.
The Acting Director did not get into specifics of OFCCP’s certification program but mentioned the Agency is asking the GSA to provide it with information on how contractors respond to the certification question in SAM and shared OFCCP will be taking a look at those answers.
With respect to all of OFCCP’s initiatives, enforcement and technical assistance alike, Acting Director Leen encouraged conference attendees to reach out to him with thoughts and suggestions.
As part of his closing remarks, Acting Director Leen expressed his gratitude for being included in such a “tremendous” conference, and remarked on the many sessions he attended and things he learned. The feelings are mutual and those in attendance appreciated the opportunity to engage (again) in information sharing with the Agency and look forward to continued opportunities to do so in the future. See you next year!