Working Together Towards Equality In The Workplace

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Date(s) - 05/08/2019
2:00 pm - 3:30 pm



Cara Crotty, NILG Board Counsel
Partner, Constangy, Brooks, Smith & Prophete

The Office of Federal Contract Compliance Programs is requesting that the Office of Management and Budget approve changes to the letters the agency uses to initiate compliance evaluations for supply and service contractors. Specifically, the agency wants to make changes to:

• Scheduling letter & itemized listing
• Compliance check letter
• Focused review letters for Section 503 & VEVRAA

For example, the OFCCP’s proposed scheduling letter for audits would require that workforce analyses be performed for each individual racial group and that goals be set for individual races as opposed to “minorities” in general. Further, the proposed itemized listing would require contractors to submit “the pool of candidates” that were considered for promotions. How many contractors can identify their three top subcontractors working on all federal contracts? And there is much more. Contractors have until June 11 to submit comments about these proposed changes.

This session will review the proposed changes for all types of audits, comparing current with the proposed scheduling letter requirements. Attendees will be asked to provide input as to opinions, burdens, and timing, and the NILG will use the attendees’ responses in its Comment to the OFCCP on its proposal.

Present: Cara Crotty, Partner, Constangy, Brooks, Smith & Prophete

Cara, the NILG Legal Counsel, advises employers on ways to avoid litigation and has defended employers in cases involving virtually every aspect of the employment relationship, including discrimination, harassment, and retaliation claims and various other federal and state law claims. Cara also represents federal contractors covered by Executive Order 11246, Section 503 of the Rehabilitation Act, and the Vietnam Era Veterans’ Readjustment Assistance Act in their affirmative action compliance obligations by assisting with Plan preparation, completion of EEO-1 and VETS-4212 Reports and defending compliance evaluations. She also prepares privileged compensation and pay equity analysis.

After registering, you will receive a confirmation email containing information about joining the webinar.