Christopher T. Patrick

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Avid readers have seen that OFCCP has been busy this summer.  In August alone, the Agency attended the 2019 ILG National Conference in Milwaukee, issued FAQs on student workers, proposed a new rule regarding religious exemptions, introduced a new Ombudsperson, opened a contractor assistance portal and issued multiple technical assistance guides.  But, OFCCP…

The official rules and authority that govern OFCCP’s actions are set forth in the federal regulations at 41 CFR 60.  These regulations go through notice and comment, as well as substantive review to ensure the appropriate balance of OFCCP’s jurisdiction and tools against the burden they pose on the contractor community.  Due to the…

Functional affirmative action plans (FAAPs) are not new.  While the regulations require AAPs be prepared on an establishment-basis, OFCCP has permitted contractors to structure their AAPs by “function” or “business unit” – with Agency approval.

Implicitly, the Agency’s 2013 Directive on the subject recognized that business structures had evolved since the 1960s.  Establishment-centered chains of…

This is the third of our series of blog posts on the Office of Management and Budget’s (OMB) July 1 request for comments on OFCCP’s updated proposed scheduling letters.  For background, OFCCP first proposed changes to its existing compliance check, establishment review, and focused review scheduling letters in April, and received comments from…

This is the second blog post in our series discussing the Office of Management and Budget’s (OMB’s) request for further comments on OFCCP’s proposed scheduling letters and itemized listings, which were first published in April.

In our April post on the proposed changes to the then newly proposed establishment review scheduling letter and itemized listing,…

In April, OFCCP proposed four new scheduling letters – one each for its establishment reviews, compliance checks, and separate but related letters for its focused reviews on Section 503 (disability) and VEVRAA (veteran) compliance. These proposed letters, if approved, would have significantly increased the burden of the submission required in the event of…

This, our third and final blog in a series discussing the proposed changes to OFCCP’s scheduling letters, takes a look at the Agency’s proposed changes to the establishment review letter and itemized listing.

With the appearance of Focused Reviews and Compliance Checks on this year’s CSAL, contractors have been abuzz about their obligations…

This is the second in our series of blogs on OFCCP’s proposed changes to its various scheduling letters.

Our previous publication focused on the Agency’s new Section 503 and VEVRAA Focused Reviews.  In addition to rolling out the new Focused Reviews, OFCCP has also revived the Compliance Check, which has not been used in…

As we reported last week, OFCCP published in the Federal Register for Notice and Comment revised scheduling letters for Section 503 and VEVRAA Focused Reviews, Compliance Checks, and regular establishment compliance reviews. As a reminder, scheduling letters initiate a compliance review and set forth the required items contractors must provide to OFCCP in an…