Among the many “hot” topics for federal contractors, OFCCP’s intention for AAP verification and/or certification ranks among the top. In September 2020, OFCCP published a notice seeking comment on the possibility of an annual AAP certification and verification process. Towards that end, the Agency also sought Office of Management and Budget (OMB) approval for an
Office of Management and Budget
Biden Administration Continues Actions Aimed at Addressing and Advancing Racial and Gender Equality
By Laura A. Mitchell on
Posted in Regulatory Update
As a follow up to the Inauguration Day recession of former President Trump’s Combatting Race and Sex Stereotyping Executive Order, the Biden Administration has issued a White House Diversity memo providing further direction on rolling back any remaining tenants of Executive Order 13950.
The memo, dated March 2, 2021, was published by the Office…
OFCCP Receives Approval of Modified Section 503 Disability Self-ID Form
By Laura A. Mitchell on
Posted in Compliance Update
OFCCP announced today it has received approval of a modified Self-Identification form for individuals with disabilities. One of the biggest changes is the form is now one page, instead of two.
OFCCP requested approval of the modified form from Office of Management and Budget (OMB) last year.
With this approval, OFCCP is giving contractors…
New OFCCP Scheduling Letters Finally Approved
By Laura A. Mitchell on
Posted in Uncategorized
At long last, OMB has finally approved OFCCP’s request to modify its scheduling letters, as well as approve a scheduling letter for VEVRAA Focused Reviews.
At first glance it appears the scheduling letters and itemized listings more resemble OFCCP’s current scheduling letters and not the Agency’s initial requested modifications.
Notably, the question…
Checking In On EEO-1 Reporting
By Laura A. Mitchell on
Posted in Uncategorized
While it feels like we just finished the EEO-1 reporting season, the time is here again to start preparing for filing of the “traditional” annual EEO-1 survey. As it has for years, EEOC will again this year look to collect race and gender data from eligible employers. Component 1 of the EEO-1 (not to be…
BREAKING NEWS: Veteran Focused Review List Released
By Laura A. Mitchell on
Posted in Enforcement Update
As promised, OFCCP has released the list of organizations that have been selected for Vietnam Era Veteran Readjustment Assistance Act (VEVRAA) Focused Reviews. The list is published in OFCCP’s FOIA Library.
Labeled as a supplement to the existing CSAL list, the new listing contains 500 establishments that will be scheduled for…
The Future of The EEO-1: What Does EEOC’s Information Collection Really Mean?
Posted in Enforcement Update, Uncategorized
As we previously reported , EEOC has filed notice asking for renewed approval to collect EEO-1 Component 1 race, gender and ethnicity workforce data for the next three years (2019, 2020 & 2021), but is not seeking renewed authority to collect Component 2 pay data and hours worked. To be clear, this filing does not…
Breaking News: EEOC Will Not Seek Renewal of Pay Data Collection At This Time
By Laura A. Mitchell on
Posted in Uncategorized
As previously reported, EEOC is expected to publish tomorrow a Notice of Information Collection regarding EEO-1 Reporting. An advance copy of the notice reports that
the EEOC is not seeking to renew Component 2 of the EEO-1.
Instead, the Commission has concluded it should consider information from the current Component 2 collection before deciding…
EEOC to Seek Public Comment on Pay Data Collection
By Laura A. Mitchell on
Posted in Uncategorized
In its required status report, filed pursuant to Court Order, EEOC announced it is preparing a Notice of Information Collection – Employer Information Report (EEO-1) to seek authorization from the Office of Management and Budget (OMB) for the collection of pay data going forward. As a reminder, OMB approval for the data collection…
OMB Seeks Public Comment on OFCCP’s Revised Scheduling Letters
By Laura A. Mitchell & James D. Mackey on
Posted in Regulatory Update
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…