A source of insights, news and strategy on affirmative action and EEO compliance matters
In a welcome turn for federal contractors, OFCCP last week submitted a proposed regulation to codify Directive 2018-01 – Use of Predetermination Notices (PDN). The regulation would require OFCCP to issue a Predetermination Notice (PDN) in every audit summarizing the Agency’s preliminary “discrimination” findings before issuing a Notice of Violation (NOV).
Regular issuance of…
Since the Government Accountability Office (GAO) issued its Recommendations to Strengthen the Office of Federal Contract Compliance Programs’ Oversight of Federal Contractors’ Nondiscrimination Compliance in July 2016, OFCCP has taken steps to implement its recommendations. And now, the GAO has issued a progress report evaluating OFCCP’s actions toward the 2016 recommendations.
The GAO’s progress…
As we noted at the beginning of the year, the Agency in late-November 2018 issued a Directive stating it would develop a dynamic and searchable publicly available source of Help Desk questions and answers to assist contractors.
Continue Reading OFCCP Issues First Opinion Letter
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…
There’s been a lot of discussion in past days about OFCCP’s new Compensation Directive, which describes the Agency’s approach to investigating pay discrimination. We’ve spent some time digging into the details of the directive. We’ve previously shared our thoughts about the Directive’s commitment to transparency, and now, as promised, want to share our…
The third of the three Directives OFCCP issued last Friday, Directive 2018-06 “Contractor Recognition Program” announces a program by which OFCCP will recognize contractors with “high-quality and high-performing compliance programs and initiatives.” Recognition is one of the four themes Acting Director Leen has spoken about recently and such programs are not a new concept in…
In the Directive released late last week, OFCCP announced its plan to start scheduling focused reviews starting in Fiscal Year 2019. OFCCP’s fiscal year begins October 1.
Directive 2018-04 directs OFCCP staff to “work towards ensuring that a portion of future scheduling lists, starting with Fiscal Year 2019, include focused reviews as to each…
Day two of the 2018 ILG National Conference has concluded and it was another day packed with information and insights for attendees.
Riding the “waves of change”, over the past two days OFCCP and officials from the U.S. Department of Labor Solicitor’s Office as well as the EEOC, have shared their insights, thoughts, and new…
In the words of OFCCP, the contractors spoke and OFCCP listened. OFCCP is also listening to the Government Accountability Office and its detailed review of the Agency.
In response to the GAO’s Strengthening Oversight Could Improve Federal Contract Nondiscrimination Compliance report and on the heels of OFCCP’s Compliance Assistance Town Halls, the Agency has…
In a year in which OFCCP has proposed and released more new and updated regulations than any other in recent memory, it looks as though they are on track to add new Sex Discrimination Regulations to the list.
Late last week, OFCCP released to OMB (the Office of Management and Budget) the Agency’s draft “final”…
