For most employers dealings with OFCCP usually come in the context of responding to a scheduling letter initiating a compliance review. There is, however, another way OFCCP can investigate an employer. Two partners from our OFCCP and Affirmative Action practice group, Matt Camardella and Eric Felsberg recently provided employers with practical pointers and advice
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OFCCP’s Budget Justification Document Further Emphasizes Enterprise-Wide Focused Reviews
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Posted in Enforcement Update
In addition to detailing it’s definition of a systemic discrimination case, OFCCP’s 2014 budget justification document also confirms the Agency’s intent to implement an enterprise-wide investigative process (as opposed to focusing on individual establishments). In its budget justification document OFCCP states that focusing on identifying issues across multiple facilities will ensure that corporate-wide changes…
OFCCP’s Budget Justification Gives Insight Into Agency’s Definition of “Systemic Discrimination”
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Posted in Enforcement Update
As we recently shared, OFCCP has issued its budget justification for fiscal year 2014. As part of this document, OFCCP shared the details of how it will define a “systemic discrimination” case.
OFCCP defines systemic discrimination as a case meeting one of two criteria:
(a) the case addresses a measurable pattern of discrimination (either…
OFCCP Asks for More Money in 2014 to Fund Expanded Pay Investigations
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In its recently released 2014 budget justification document OFCCP sought an approximate $1.1million dollar funding increase over 2013 levels. Following on the heels of its rescission of the 2006 Compensation Standards and Guidelines and implementation of Directive 307, OFCCP states the influx of cash will go to fund the Agency’s continued quest to “narrow…
Breaking News: OFCCP Sends Out Large Wave of Advance Notice Letters Notifying Employers of Compliance Audits
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Posted in Compliance Tip, Enforcement Update
On March 27, 2013 OFCCP sent out a wave advance notice letters –referred to as CSAL’s – to employers across the country. In November, 2012, OFCCP emailed more 1,750 CSALs. We have learned the number of CSAL’s mailed last week exceeds the last round of notifications sent in November. As result, employers can expect…
OFCCP Offers Insights Into Agency’s New Compensation Directive
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Posted in Enforcement Update
In a public webinar held earlier this week, OFCCP provided listeners with information and insights into the Agency’s recent rescission of the 2006 Compensation Standards and the implementation of Directive 307.
As OFCCP’s Notice of Rescission made clear, the Agency felt constrained by the 2006 Standards and the new “case-by-case” approach to pay investigations will…