The National Industry Liaison Group has worked with OFCCP leadership to clarify contractor obligations and OFCCP expectations for compliance reviews that are moving forward during this unprecedented time.  The below are in addition to the National Interest Exemption recently announced by the Agency.

By e-mail, NILG shared OFCCP has informed it of the following protocols the Agency will put in place going forward:

  • Grant an automatic 30-day extension for submission of AAPs after receipt of Scheduling Letter
  • Grant an automatic additional 30-day extension to contractors who submit their written AAP narrative within 60 days of receipt of scheduling letter (i.e. provide another 30 days for submission of all data reports and analyses)
  • Grant an automatic extension of 14 days, and more commonly of 30 days, for contractor response to information requests, with opportunity for further extensions as needed
  • Conduct 503 focused review onsites via video or phone conference only until contractors begin resuming normal operations

The protocols will allow OFCCP to continue operations to the extent feasible given the current emergency as well as address contractor concerns as their operations become impacted by the pandemic.  The key, as it always should be, is for contractors to communicate with OFCCP during an audit to the best extent possible.

The OFCCP and the NILG recommend contractors concerned about receiving Scheduling Letters during the emergency consider providing an email address for the responsible contractor representative to the applicable Regional Director, with a copy to Deputy Director Patricia Davidson at  Davidson.Patricia@dol.gov.  The OFCCP assures the NILG that

contractors providing this information will receive the Scheduling Letters via email in addition to the mailed copy.

OFCCP and NILG recommend that “contractors who believe the OFCCP is not taking the pandemic emergency into sufficient account, either in general or in a relation to a specific audit,” contact the OFCCP Omsbud, Marcus Stergio,  Stergio.Marcus@dol.gov or 202-693-1174.

NILG and the contractor community appreciate Director Leen’s and the Agency’s swift attention to these matters during these trying times.

Be Safe and Stay Well.

Tags: Director Craig Leen, Marcus Stergio, National Industry Liaison Group, NILG, OFCCP, Office of Federal Contract Compliance Programs, Patricia Davidson
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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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