Our comments to OFCCP in response to the agency’s announced intent to revise its compliance evaluation “Scheduling Letter” question whether a projected 35% increase in the burden imposed on federal contractors will make the audit process more “effici
OFCCP has posted a new Corporate Scheduling Announcement List identifying 500 federal contractor establishments that it intends to audit in the near future. Unlike the essentially random methodology employed in generating previous CSALs, OFCCP is exp
CWC has filed written comments with OFCCP asking the agency to relax its rigid requirement that federal contractors must use the agency’s prescribed disability self-ID Form CC-305 despite ample evidence that the form is not effective in encouraging i
MEMBER FEEDBACK REQUESTED. Our recent members-only roundtable featured a robust discussion of proposed changes that OFCCP wants to make to its compliance evaluation Scheduling Letter and Itemized Listing, with participants expressing concern regardin
MEMBER FEEDBACK REQUESTED. OFCCP is proposing some minor changes to the form (CC-305) it requires federal contractors to use to allow individuals to voluntarily self-ID their disability status. CWC plans to submit comments with OFCCP urging further i
MEMBER FEEDBACK REQUESTED. Less than ten years after OFCCP made extensive changes to its scheduling letter and accompanying “itemized listing” that required federal contractors to submit substantially more data, the agency is proposing to do so again
The Supreme Court is considering legal challenges brought against two universities claiming that race-based considerations used in their admissions policies are unlawful. The cases are the first that the High Court has heard in many years on the lega
Now that OFCCP is requiring federal contractors to post the EEOC’s new “Know Your Rights” poster, we thought it would be helpful to update our guide on all current OFCCP posting requirements.
As expected, OFCCP has informed federal contractors that they must begin using the EEOC’s new “Know Your Rights” poster to replace the familiar “EEO is the Law” poster and poster supplement that contractors have been using for years to meet OFCCP pos
We expected the Biden Administration’s Labor Department to be more aggressive in filing formal OFCCP-related administrative lawsuits, but that hasn’t been the case until now. Things may be changing, however, as our memo explains.
MEMBER FEEDBACK REQUESTED. OFCCP regulations require covered federal contractors to make their Section 503/VEVRAA AAPs “available” to applicants and employees upon request. The regulations don’t address how this should be done in a remote work enviro
OFCCP has received approval from the White House Office of Management and Budget to continue its Functional Affirmative Action Program option for another three years. The program as extended contains some welcome improvements that may encourage great
Our latest update of OFCCP financial settlements summarizes seven new settlements posted by the agency since our last update in May.
WEB WORKSHOP SCHEDULED. OFCCP has issued a revised “compensation analysis” directive clarifying that agency compliance officers will not demand an analysis prepared under an applicable legal privilege as OFCCP claimed it had the right to do under the
MEMBER FEEDBACK REQUESTED. CWC is pleased to announce the launch of our new Integrating Compliance and Diversity, Equity & Inclusion memo series, leading with this introductory primer on the proper use of OFCCP-required “placement goals” for women an
In an announcement last week that also indicates its online AAP-VI Portal remains open despite a June 30 certification deadline, OFCCP has clarified that federal contractors that have not yet certified but have a pending Help Desk request made before
Our memo provides the latest information regarding the “HIRE” initiative, a joint effort between the EEOC and OFCCP launched last January that is designed to “identify strategies to remove unnecessary barriers to hiring and to promote effective, job-
While there has been no official announcement from OFCCP, the online Affirmative Action Program Verification Interface (AAP-VI) Contractor Portal is still open, despite a June 30 certification deadline. Our memo delves into the possible reasons why.
CWC has filed written comments with the Office of Management and Budget urging it to approve OFCCP’s request to extend the Functional Affirmative Action Program (FAAP) application and approval process for another three years, albeit with one minor ch
As the June 30 deadline for federal contractors to certify with OFCCP’s new AAP-VI approaches, many CWC members have questions about what it means to have “developed and maintained” their AAPs. Our memo and attached checklist provide guidance.
MEMBER FEEDBACK REQUESTED. OFCCP is seeking approval from the White House Office of Management and Budget to extend the Functional Affirmative Action Program option for another three years, a move that CWC supports.
In a new FAQ posted to its AAP-VI portal late last week, OFCCP has reversed course and is now saying that contractor establishments with fewer than 50 employees must be included if the contractor maintains an AAP for that site, even though not requir
A federal trial court in Texas has ruled that a legal challenge by that state to expanded guidance on sexual orientation/gender identity guidance issued by the EEOC last year can proceed, rejecting the Administration’s various arguments that the laws
Sometime in the next few months, OFCCP is expected to publish a formal proposal to modernize its “60-2” AAP regulations. Our memo proves a preview of some of the things it is likely to include.
Our most recent member roundtable featured a lively discussion among participants and CWC’s staff experts on the practical implications of OFCCP Director Jenny Yang’s new enforcement directive.
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