Ahead of the start of the 2024 National ILG Conference, OFCCP announced today publication of Directive 2024-01: Expedited Conciliation Procedures.

In its announcement OFCCP described the directive as

outlining updated procedures for an expedited conciliation option, giving contractors and the agency flexibility in the resolution of violations.

More specifically, OFCCP explained the new directive is the agency’s way of “align[ing the conciliation] process with OFCCP’s final rule, Pre-Enforcement Notice and Conciliation Procedures, published on August 4, 2023. The new Directive 2024-01 rescinds and replaces DIR 2019-02, Early Resolution Procedures. 

Among other procedures, the new directive sets out a timetable for the review and consideration of expedited conciliation by both OFCCP and the contractor, with the first proscribed deadline occurring 14 days after the conclusion of the desk audit, at which time,

when possible, the Investigator must discuss the desk audit findings and potential for expedited conciliation with the district and regional office management. 

We are continuing to review the new directive and look forward to hearing OFCCP’s thoughts and comments next week in Orlando.

Tags: 2024 NILG Conference, conciliation, Directive 2024-01, National ILG, NILG, OFCCP, Office of Federal Contract Compliance Programs, PDN, Pre-Enforcement Notice, Pre-enforcement Notice and Conciliation Procedures, Predetermination Notice
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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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