OFCCP Director Craig Leen thinks the Agency has made good progress on implementing “the four pillars” but there is still work to be done. Speaking this week in Florida, Director Leen shared accomplishments, and things to come, for each of the four tenants. However, he noted he was not allowed to comment on the pending … Continue Reading
It’s time to start checking the mail. As a sure indication of the Agency’s intention to soon start initiating audits from the FY2019 CSAL, OFCCP has published a new Compliance Check website. OFCCP has published similar guidance for the Section 503 Focused Reviews. In furtherance of its commitment to provide more technical assistance, OFCCP created with … Continue Reading
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 associated with … Continue Reading
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 recent years. … Continue Reading
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 audit. Over the … Continue Reading
Last Week, OFCCP Director Craig Leen and Deputy Assistant Secretary of the Office of Disability Employment Policy (“ODEP”) Jennifer Sheehy, joined with the National Industry Liaison Group to discuss disability and inclusion. With 500 Section 503 Focused Reviews on OFCCP’s March 2019 CSAL list, the timing was perfect to hear directly from the OFCCP Director … Continue Reading
On April 12, 2019, OFCCP posted on the Federal Register for Notice and Comment revised scheduling letters for Section 503 and VEVRAA Focused Reviews, Compliance Checks and regular establishment compliance reviews. The proposed Establishment and Focused Review scheduling letters significantly increase the data submission required for veterans and individuals with disabilities, including hiring and compensation information. Comments are due June … Continue Reading
In furtherance of its work as an enforcement agency and its commitment to conduct reviews of more contractors, OFCCP posted in the Federal Register on Monday, April 8, 2019 its proposal for a series of compliance check audit letters for construction contractors. The agency is request feedback on two proposed construction compliance check letters – federally assisted versus a direct federal … Continue Reading
Just in time for its next round of audits, OFCCP has released its annual review of the Vietnam Era Veterans Readjustment Assistance Act (“VEVRAA”) benchmark. And for the fifth consecutive year, the benchmark has been reduced benchmark. It is now at 5.9%. The new benchmark will be effective for affirmative action plans updated after March … Continue Reading
Today, OFCCP issued its first Corporate Scheduling Announcement List (CSAL) of 2019, providing advance notification of compliance reviews, including CMCEs, Section 503 Focused Reviews and compliance checks. True to expectations, the Agency vastly increased the number of locations subject to review to more than 3,500. OFCCP continued its new policy of transparency by publishing the list of … Continue Reading
In August 2018, OFCCP released Directive 2018-04 announcing the Agency’s implementation of Section 503 Focused Reviews. Long a priority Director Craig Leen, the Agency is hopeful the reviews will improve compliance with the regulations and promulgate EEO for Individuals with Disabilities. OFCCP has indicated it will start scheduling the Section 503 Focused Reviews with the … Continue Reading
OFCCP announced Friday that it will post a new Corporate Scheduling Announcement List (CSAL)(formerly known as Corporate Scheduling Announcement Letter or Courtesy Scheduling Announcement Letter) in “mid-to-late March.” As previously announced, OFCCP now makes the CSAL publically available and, for the first time, OFCCP will send no letters to federal contractors – thus the changed reference to … Continue Reading
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 … Continue Reading
Last August we reported on OFCCP’s announcement (DIR 2018-04) that starting in 2019 it would be conducting truncated “Focused Reviews” that centered on compliance with AAP requirements under Section 503 (Individuals with Disabilities) and VEVRAA (Veterans). If everything goes according to OFCCP’s plan, the next round of CSALs will include notices for these more limited Focused … Continue Reading
As part of OFCCP’s continuing efforts at transparency, the Agency in late-November 2018 issued a Directive stating it would develop “a dynamic and searchable publically available source of Help Desk questions and answers to assist contractors.” Moreover, the Directive announced OFCCP would issue Opinion Letters to provide guidance on specific topics, either in response to … Continue Reading
As OFCCP heads into 2019, with an official Director in place, the Agency is looking towards implement many of its new Directives released in the second half of 2018. Back in September, we discussed OFCCP Directive 2018-09: OFCCP Ombud Service, one of the number of policy changes OFCCP hoped to develop to increase a sense … Continue Reading
As reported by Bloomberg Law, and reflected on OFCCP’s website, former OFCCP Acting Director Craig Leen has now been formally named Director of OFCCP. Since being placed in the acting role this past Summer when the position was vacated by Ondray Harris, Leen has overseen the release of ten new directives and has worked tirelessly to rebuild the … Continue Reading
In preparation for the 2019 launch of its veteran hiring initiative, the Department of Labor announced a list of award recipients for its pilot “HIRE VETS Medallion Program Demonstration Award” on Wednesday, December 19. President Trump signed the HIRE (Honoring Investments in Recruiting and Employing American Military Veterans) Vets Act on May 5, 2017. HIRE … Continue Reading
With less than a week left on the December 21st deadline to reach a spending deal and avoid another government shutdown, tensions are high in Washington D.C. On Tuesday, President Trump stated he would refuse to sign a spending bill that did not contain a $5 billion allocation for a border wall. It is questionable, … Continue Reading
As we reported on Friday, November 30, OFCCP began it’s 2019 fiscal year by releasing a rash of new directives. On Monday, we looked at the rescission of Obama Administration’s Active Case Enforcement (ACE) directive. Yesterday, we reviewed OFCCP’s new guidance on Early Resolution Procedures. Today we review the third Directive – Directive 2019-03: Opinion … Continue Reading
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 (effective November … Continue Reading
Last Friday, OFCCP kicked off the 2019 fiscal year with its first of three new Directives: “Directive 2019-01 – Compliance Review Procedures,” which rescinds the Obama Administration’s Active Case Enforcement (ACE) approach to audits – Directive 2011-01. The ACE Directive was itself a replacement of the Bush Administration’s Active Case Management Directive (ACM). What does … Continue Reading
Today, on the last day of the month, OFCCP has released three new directives – the first three of the Agency’s 2019 Fiscal Year – and continues the string of directives issued by the new administration, bringing the number to an even dozen. Directive 2019 -01: Compliance Review Procedures rescinds the Directive 2011-01 which set out the Active … Continue Reading
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 every stage of the compliance evaluation, … Continue Reading
