Archives: Enforcement Reminder

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OFCCP – Here to Stay or Not? Signs Indicate OFCCP Will Survive

With the transition to a new presidential administration well under way, everyone is looking for signs to help predict the future.  Given President Trump’s sweeping executive action, including entering an Executive Order requiring the identification of two regulations to be eliminated for every new regulation proposed, the question of whether the make-up of the federal agencies as we … Continue Reading

Pay Transparency Obligations Are Now Effective

Happy New Year!  For the government contractor community 2016 seems to be picking up right where 2015 left off  – with implementation of new compliance obligations. Eleven days into the new year and federal contractors are now subject to Executive Order 13665 – the Pay Transparency Executive Order.  While January 11, 2016 is officially the first day government contractors can … Continue Reading

Protecting Your Proactive Pay Analyses

The Obama Administration has made it clear that closing the persistent gender “wage gap” is one of its top EEO priorities. As such, OFCCP has ramped up its enforcement of equal pay laws, including rewriting its compensation investigation guidelines with Agency Directive 307, revamping its Division of Statistical Analyses, and reinventing the pay data component … Continue Reading

Greetings from the 2014 SWARM Regional Conference

Good Morning Folks!  We just listened to Melissa Speer, OFCCP SWARM Regional Director, open up the 2014 SWARM Regional Conference from the beautiful Omni Interlocken Hotel in Broomfield, Colorado.  As you can imagine Melissa had a lot of new OFCCP developments to chat about, including the recent Presidential executive actions surrounding pay discrimination as well … Continue Reading

Dissemination of Your EEO Policy: Are You Requesting “Cooperation” and “Appropriate Action” from Your Unions and Vendors?

With March 24th come and gone many employers are still working on implementing the required elements of OFCCP’s new veteran and disability regulations and making preparations for rolling-out Subpart C compliance measures. As of March 24th, contractors who are party to a collective bargaining agreement (CBA)  “shall notify union officials and/or employee representatives to inform them of … Continue Reading

Which is Which: Getting All the Required EEO Notices in Place in Time for March 24th

As the last few days before the new veteran and disability regulations go into effect, we wanted to take moment in our  Countdown to March 24th Effective Date: Are you Ready to Flip the Switch series to help you clarify (and check-off) the obligations with respect to the various EEO notices, policy and posting requirements under the … Continue Reading

Assessing the Effectiveness of Your Outreach Efforts after March 24th

In today’s post as part of our “Countdown to March 24th Effective Date: Are you Ready to Flip the Switch?” series, we’ll be discussing the new obligation under the veterans and disability regulations that employers must now “assess the effectiveness” of their good faith outreach programs. Back in 2011 when OFCCP first released the proposed … Continue Reading

Notifying Applicants of EEO Rights…after Monday March 24, 2014

As the next installment of our “Countdown to March 24th Effective Date: Are you Ready to Flip the Switch?” let’s take a look at what employers need to be telling Job Seekers after March 24th . . . A number of the new veteran and disability obligations effective March 24, 2014 involve notifying job seekers that your … Continue Reading

Countdown to March 24th Effective Date: Are you Ready to “Flip the Switch?”

Today will mark the first in a series of posts over the next week counting down to the March 24th effective date for OFCCP’s new Veteran and Disability regulations. During the next week we will seek to provide you with practical pointers and tips as you work through your checklists and prepare to “flip the … Continue Reading

Requirement to Post Union Rights Still in Effect for Federal Contractors

Earlier this month the NLRB  decided not to appeal two appellate court decisions invalidating the NLRB’s 2011 adoption of a rule requiring private sector employers to post notices advising employees of their rights under the National Labor Relations Act.  The decision to allow this deadline to pass rendered the posting obligations “dead in the water” for … Continue Reading

Veterans Day: A Reminder of OFCCP’s Continued Aggressive Enforcement Agenda

As the country honors all of the men and women who have sacrificed to serve our country, it is a good time to assess compliance with veteran focused OFCCP obligations.    Not missing a chance to focus on employing veterans, Department of Labor Secretary Hilda Solis issued a statement urging employers to commemorate the Veterans … Continue Reading