OFCCP compliance review

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

The Department of Labor has announced updates to the Notification of Employee Rights Under Federal Labor Law poster, required to be posted (in 11×17 format) by federal contractors and subcontractors pursuant to Executive Order 13496.

The changes include:

  • a new telephone number for the National Labor Relations Board (NLRB), the agency responsible for enforcing

As we reported last Friday, OFCCP has kicked-off 2019 with a bang – issuing three directives in a single day.

Yesterday we reported on the first of three new Directives OFCCP issued to kick off fiscal year 2019. Today we cover the second Directive – Directive 2019-02: Early Resolution Procedures.

Under Directive 2019-02

There is no rest for the weary at OFCCP.  Continuing the steady flow of Directives and proposals as well as audits coming out of Washington D.C., the Agency has released two additional directives in furtherance of the Administration’s commitment to transparency and certainty.

The first, Directive 2018-08: Transparency in OFCCP Compliance Activities  will “ensure