Checking off another of the Agency’s “To Dos”, OFCCP has published revisions and updates to the Federal Contractor Compliance Manual (FCCM).  The manual is the Agency’s “instruction manual” providing

guidance for OFCCP’s compliance officers in conducting compliance evaluations and complaint investigations . . .

Revisions to the guide have been promised for years, and the Agency under the leadership of Director Craig Leen has finally accomplished it in furtherance of its commitment to transparency to the contractor community.

The Agency has made changes to a good number of the Manual’s sections but they’ve emphasized highlight the following changes:

  • Revisions to align with the Agency’s new directives
  • Addition of protected bases to align with OFCCP’s authority
  • Updated language and direction with respect to disability and veteran requirements

The Agency has published a list of the changes but encourages review of “the entirety of the referenced section(s) in which an update occurred . . . in order to better understand the full context of the update.”

We are in the process of digesting and comparing the this new version of the manual to the previous edition and will be back soon with more specific insights.

Tags: Director Craig Leen, disability affirmative action, FCCM, Federal Contractor Compliance Manual, OFCCP, Office of Federal Contract Compliance Programs, Section 503, veteran affirmative action, VEVRAA
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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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