Agency Enforcement

Memo
25-044
Tuesday, March 4, 2025

With Executive Order 11246 now rescinded, OFCCP has formally terminated all FAAP agreements that were maintained between the agency and federal contractors. The agreements permitted contractors to structure their AAPs by function rather than location


Memo
25-037
Tuesday, February 25, 2025

We’ve updated our equal opportunity and affirmative action policy templates to reflect rescission of E.O. 11246. These templates can be helpful to federal contractors as they review equal opportunity and affirmative action policies to ensure complian


Memo
25-024
Wednesday, February 5, 2025

CWC held a members-only roundtable on January 29 to explain the ramifications of President Trump’s new executive order that rescinded long-standing Executive Order 11246.


Memo
25-023
Tuesday, February 4, 2025

The Trump Administration has appointed Michael Schloss as the Deputy Director of Policy and Acting Director at the Office of Federal Contract Compliance Programs (OFCCP). Schloss previously served as a career employee in the Labor Department’s Employ


Memo
25-016
Monday, January 27, 2025

Acting Labor Secretary Vincent Micone has ordered DOL personnel to cease and desist all enforcement activities under rescinded E.O. 11246, while Section 503 and VEVRAA enforcement activities are paused pending further guidance.


Memo
25-014
Thursday, January 23, 2025

MEMBER ROUNDTABLE SCHEDULED. President Trump has rescinded Executive Order 11246. While there are still more questions than answers about this major policy shift, our memo summarizes what we know thus far and outlines many of the contractor complianc


Memo
25-004
Thursday, January 9, 2025

The EEOC and OFCCP have renewed their long-standing Memorandum of Understanding governing information sharing and charge processing, with some important revisions. Our memo explains.


Memo
24-208
Thursday, December 19, 2024

According to OFCCP’s recently released enforcement data for FY 2024, the number of compliance audits completed hit a new low last year. However, the agency alleged many more violations on the basis of disability and protected veteran status.


Memo
24-207
Tuesday, December 17, 2024

A federal district court ruled that the Naval Academy’s use of race in admissions is constitutional, distinguishing the case from last year’s landmark Supreme Court decision in Harvard.


Memo
24-200
Tuesday, December 3, 2024

Employers with a federal construction contract or subcontract or federally assisted construction contract or subcontract in excess of $10,000 must submit monthly Form CC-257 reports to OFCCP starting April 15, 2025.


Memo
24-197
Thursday, November 21, 2024

OFCCP’s latest Corporate Scheduling Announcement List (CSAL) puts some 2,000 federal contractor entities on notice that they’ve been flagged for an upcoming compliance audit.


Memo
24-171
Thursday, October 10, 2024

OFCCP has received approval to begin collecting monthly reports from construction contractors detailing employee count and work hours by race/ethnicity, sex, and construction trade.


Memo
24-138
Thursday, August 15, 2024

Our comments to the White House Office of Management and Budget argue that it should not give permission to OFCCP to reinstate a burdensome form that OFCCP discontinued decades ago because it was marginally useful and put a strain on agency resources


Memo
24-132
Tuesday, August 6, 2024

CWC is pleased to provide our members with an updated template to assist in meeting their employment service delivery system (ESDS) notice obligations required under OFCCP regulations.


Memo
24-129
Monday, August 5, 2024

The White House Office of Management and Budget has given OFCCP the go-ahead to begin using a new and expanded version of the Scheduling Letter used to notify federal construction contractors of a compliance audit.


Memo
24-128
Thursday, August 1, 2024

OFCCP’s new directive retains many of the components of the prior administration’s “early resolution conciliation” procedures. Whether it signals a change in OFCCP’s current enforcement philosophy remains to be seen.


Memo
24-124
Wednesday, July 24, 2024

Our comments to the White House Office of Management and Budget urge that agency to require OFCCP to make revisions to its proposed construction contractor scheduling letter before OMB gives approval to OFCCP to use it.


Memo
24-120
Thursday, July 18, 2024

MEMBER FEEDBACK REQUESTED. OFCCP is asking OMB for approval to reinstate a burdensome reporting requirement on federal construction contractors that the agency originally abandoned in 1995 as putting a strain on OFCCP resources.


Memo
24-114
Tuesday, July 9, 2024

OFCCP has announced 16 formal settlements of enforcement actions against federal contractors during the first three quarters of the fiscal year. Our memo provides details.


Memo
24-110
Monday, July 1, 2024

MEMBER FEEDBACK REQUESTED. OFCCP has asked OMB for approval to use a more detailed scheduling letter and itemized listing for compliance reviews of construction contractors. While the agency rejected our recommendations, its response provides some in


Memo
24-107
Wednesday, June 26, 2024

As the July 1 certification deadline approaches, technical issues have once again frustrated OFCCP’s Contractor Portal certification process.


Memo
24-104
Tuesday, June 18, 2024

Our comments to the Office of Management and Budget argue that OFCCP’s Contractor Portal remains overly burdensome to federal contractors, and that changes should be made before it is extended for another three years


Memo
24-100
Wednesday, June 12, 2024

The ruling by a divided federal appeals court signals another potential setback for corporate programs designed to advance DEI initiatives.


Memo
24-084
Thursday, May 16, 2024

MEMBER FEEDBACK REQUESTED. OFCCP has filed a formal request with the White House Office of Management and Budget to continue using its Contractor Portal for another three years. OMB is accepting comments on OFCCP’s request, and CWC intends to comment


Memo
24-079
Thursday, May 9, 2024

Federal contractors may find helpful a new guidance document published by OFCCP that outlines the risks and obligations that are potentially triggered by the use of AI and other automated systems in the workplace.


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