Monthly Archives: January 2020


OFCCP Updates The Federal Contract Compliance Manual

2020-01-20T23:58:37+00:00January 20th, 2020|OFCCP|

On December 30, 2019, OFCCP updated its Federal Contract Compliance Manual (FCCM) for the first time since 2014.  The FCCM “provides guidance for OFCCP’s compliance officers . . . in conducting compliance evaluations, complaint investigations and providing federal contractors with compliance assistance.” In a press release, OFCCP explained that the updates “reflect revisions to OFCCP’s

Join Our Webinar: OFCCP – The Year That Was and the Year Ahead

2020-01-20T23:58:36+00:00January 20th, 2020|OFCCP|

Join us for a webinar on Wednesday, January 15, 2020, to review the significant changes and initiatives implemented by the Office of Federal Contract Compliance Programs in 2019, what they mean for federal contractors and what federal contractors can expect in 2020. Partner Guy Brenner and labor economist Dr. Rick Holt, a Director at Resolution

OFCCP Proposes Rules Codifying Procedures for Resolving Alleged Violations and Setting Thresholds For Discrimination Findings

2020-01-20T23:58:35+00:00January 20th, 2020|OFCCP|

Quick Hit: OFCCP has published a Notice of Proposed Rulemaking (NPRM) it states would “codify the procedures that the agency currently uses to resolve potential discrimination and other material violations” and “clarify definitions to specify the types of evidence OFCCP will use to support its discrimination findings.”  The procedures dictate OFCCP’s use of Predetermination Notices

OFCCP Will Not Use EEO-1 Component 2 Data In Audits

2020-01-20T23:58:34+00:00January 20th, 2020|OFCCP|

On November 22, 2019, OFCCP announced it will not “request, accept, or use” EEO-1 Component 2 pay and hours worked data from government contractors in connection with audits (or otherwise). OFCCP explained that it will not request or use the data because it is “collected in a format that is highly aggregated” and, therefore, is

OFCCP Directive: Audits Will Investigate Discrimination Against Spouses Of Protected Veterans

2020-01-20T23:58:33+00:00January 20th, 2020|OFCCP|

On November 8, 2019, just before Veterans Day, OFCCP issued Directive (2020-01) (the “Directive”), which addresses “Spouses of Protected Veterans.”  Its latest directive is the first of FY2020 and follows up on the agency’s supplemental CSAL identifying contractors selected for VEVRAA Focused Reviews. The Directive observes that spouses of protected veterans are protected by OFCCP

OFCCP Issues Supplemental CSAL – Were You Selected For A New VEVRAA Focused Review?

2020-01-20T23:58:32+00:00January 20th, 2020|OFCCP|

On November 8, 2019, OFCCP released its Corporate Scheduling Announcement List (“CSAL”) Supplement.  The list identifies 500 establishments selected for the new VEVRAA focused review compliance evaluation.  In 2018, OFCCP announced that it would be conducting focused reviews during which it would target its analysis on contractors’ compliance with  Executive Order 11246 (the “EO”) (equal

OFCCP Sets New Record For Bias Settlements In FY19

2020-01-20T23:58:31+00:00January 20th, 2020|OFCCP|

Any illusions that OFCCP would disappear during the Trump Administration should have already been put to rest with the nearly non-stop activity of the agency since 2017.  But to the extent there was any remaining doubt, a recent report about the monetary recoveries secured by the agency should put that to rest. As OFCCP announced,

OFCCP Proposes Changes to the Self-Identification of Disability Form

2020-01-20T23:58:30+00:00January 20th, 2020|OFCCP|

On October 3, 2019 OFCCP submitted a request to the Office of Management and Budget for approval of proposed changes to its Voluntary Self-Identification of Disability Form.  OFCCP explained that it had proposed the changes “in an effort to increase the response rate on the form.” The proposed changes include: Removing the reasonable accommodation notice;

GAO Report Assesses OFCCP Progress and Indicates Annual AAP Collection Not Far Off

2020-01-20T23:58:29+00:00January 20th, 2020|OFCCP|

The Government Accountability Office (GAO) recently released a report (the “2019 Report”) evaluating the Office of Federal Contract Compliance Program’s (OFCCP) implementation of the GAO’s 2016 and 2017 recommendations for improving oversight of contractor compliance. The 2019 Report concludes that OFCCP has implemented only 4 of the GAO’s 11 recommended changes. The key findings and