As we previously reported, on July 2, EEOC updated the its newly created website with long-awaited materials regarding the obligation of employers with 100 or more employees to submit pay data and hours worked data as part of the annual EEO-1 reporting obligations.

We anticipated EEOC would not change much relative to the materials

On Friday, the Office of Management and Budget (OMB) published notice it would begin reviewing the proposed changes to OFCCP’s Supply and Service scheduling letters, including the Section 503 and VEVRAA Focused Reviews and Compliance Check letters. OMB is seeking public comments until July 29, 2019 to aid in its review.  Under the Paperwork Reduction

In its most recent status update, filed with the court as ordered by Judge Tanya S. Chutkan, EEOC is reporting it and NORC are on schedule to open the EEO-1 Component 2 pay data reporting tool on July 15, 2019.

The status report explained that a Computer-assisted Web Interview (CAWI) data collection instrument will be available on July 15, 2019. Importantly, the report noted that NORC is working on a data file upload function and validation process which is expected to be available as an additional data collection method no later than August 15, 2019.


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This week the Department of Labor announced its spring 2019 Regulatory Agenda.   Included was an new item from OFCCP that was part of its prior published regulatory agenda.  As OFCCP previously announced in 2018, its planned rule-making agenda for the near future includes rulemaking to address affirmative action obligations for TRICARE providers (slated for May 2019) and contractor’s use of religious exemptions (slated for June 2019).

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On the eve of St. Valentine’s Day, OFCCP is wanting contractors to feel the love.  In its fourth directive of fiscal year 2019, OFCCP has unveiled a Voluntary Enterprise-wide Review Program, otherwise referred to as VERP.  Directive 2019-04 states VERP

enables OFCCP to blend its compliance evaluation and compliance assistance activities to work with high‐performing

By Laura A. Mitchell and Suzanne Donnelly Corwin

Late last week, OFCCP published a notice in the federal register seeking public comment regarding its proposed Leadership in Equal Access and Diversity (“LEAD”) Award.  The LEAD award will

 recognize federal contractor and subcontractor establishments that have developed and successfully implemented comprehensive equal employment opportunity and