In an effort to provide additional guidance to employers navigating the new Component 2 pay data filing requirements, the Equal Employment Opportunity Commission (EEOC) and NORC have just updated its frequently asked questions (FAQs) with respect to how employers experiencing mergers, acquisitions, and spinoffs during 2017 and 2018 should be filing their 2017 and 2018
Suzanne Donnelly Corwin
Updated Proposed Focused Review Scheduling Letters: OFCCP Still Seeks Substantive Revisions
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…
OFCCP Scales Back its Proposed Changes to the Establishment Review Scheduling Letter Itemized Listing
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,…
What’s New with the Updated Proposed Compliance Check Scheduling Letter?
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…
OFCCP Establishment Review Scheduling Letter Updates
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…
OFCCP Proposes Revised Scheduling Letter for Compliance Checks
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…
OFCCP’s Agenda for 2019: More Audits and Increased Transparency
As contractors start to see new scheduling letters arrive from OFCCP’s latest round of advance notification letters, OFCCP has new opportunities to demonstrate its commitment to transparency, through implementation of the Agency’s recently released Directive 2018-08: Transparency in OFCCP Compliance Activities. The Agency’s stated philosophy is that transparency should “guide OFCCP staff during…
New Compensation Directive Promises Transparency
Late last week OFCCP released a new Directive detailing the Agency’s approach to investigating pay discrimination. Directive 2018-05 applies to all OFCCP reviews scheduled on or after August 24, 2018, and to open reviews to the extent “they do not conflict with OFCCP guidance or procedures existing prior to the effective date.”
Over the coming…