Today, on the last day of the month, OFCCP has released three new directives – the first three of the Agency’s 2019 Fiscal Year – and continues the string of directives issued by the new administration, bringing the number to an even dozen.
Directive 2019 -01: Compliance Review Procedures rescinds the Directive 2011-01 which set out the Active Case Enforcement compliance review procedures implemented under former Director Patricia Shiu and states reviews will be conducted in accordance with the Agency’s Federal Contract Compliance Manual (FCCM).
Directive 2019-02: Early Resolution Procedures is intended to create a path to “help contractors and OFCCP achieve their mutual goal of equal employment opportunity in federal contracting and reduce the length of compliance evaluations through early and efficient resolutions.”
Directive 2019-03: Opinion Letters and Help Desk sets forth the Agency’s intention to enhance is technical assistance tools by development of a searchable Help Desk question repository. The Directive also formally sets forth OFCCP’s intention to start issuing Formal Opinion letters.
We are in the process of digesting these directives and will follow up with more in-depth analysis and insights in the coming days.