Comments and Testimony

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
24-104
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
23-214
Tuesday, November 7, 2023

Our comments to the EEOC on its proposed new guidance on unlawful workplace harassment commend the agency for its effort to reflect changes in law and policy that have occurred in recent years, but also express concerns about proposed policy interpre


Memo
23-105
Wednesday, May 24, 2023

CWC’s written comments to the Office of Management and Budget contend that burdensome changes that OFCCP is proposing to its compliance evaluation scheduling letter are neither warranted nor likely to increase agency efficiency.


Memo
23-087
Monday, May 1, 2023

Our written comments to the White House Office of Management and Budget are in response to preliminary proposals for revising the government’s race/ethnicity data collection and reporting standards, and explain how those changes would impact complian


Memo
23-084
Wednesday, April 26, 2023

CWC has filed comments with the White House Office of Management and Budget urging that agency to mandate sensible changes to OFCCP’s overly prescriptive Form CC-305 before giving OFCCP clearance to continue using the form for another three years.


Memo
23-083
Tuesday, April 25, 2023

CWC has filed written comments with the Federal Trade Commission asking the agency to withdraw a proposed rule that would ban the use of most non-compete agreements.


Memo
23-063
Tuesday, March 28, 2023

CWC has filed a comment letter with OFCCP expressing conditional support for the agency’s intent to implement a new “intake” form as part of OFCCP’s formal discrimination complaint process.


Memo
23-036
Thursday, February 16, 2023

Our comments to the Equal Employment Opportunity Commission on its proposed 2023-2027 “Strategic Enforcement Plan” urge the agency to expedite compliance guidance on the recently enacted Pregnant Workers Fairness Act, while also offering several reco


Memo
23-024
Tuesday, January 31, 2023

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


Memo
23-019
Wednesday, January 25, 2023

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


Memo
23-014
Wednesday, January 18, 2023

CWC has filed written comments with the Equal Employment Opportunity Commission in support of the agency’s announced intent to get approval from the White House Office of Management and Budget to continue using a slightly revised version of the EEO-1


Memo
22-233
Wednesday, December 14, 2022

Our written comments to the National Labor Relations Board argue that its proposal to abandon the balanced test for determining joint employment liability established by the Board in 2020 will unfairly skew the law to favor joint employer findings.


Memo
22-230
Monday, December 12, 2022

Our written comments to the Equal Employment Opportunity Commission on its draft “Strategic Plan” for 2022-2026 urge the agency to include metrics that will encourage quality charge investigations, with less emphasis on conducting resource-intensive


Memo
22-203
Tuesday, October 25, 2022

CWC’s written comments to the Department of Homeland Security argue that two years of positive experience by employers is more than enough to justify making permanent the current temporary policy of allowing I-9 verifications to be completed remotely


Memo
22-195
Wednesday, October 12, 2022

CWC’s written comments to the EEOC offer recommendations for issues to include as the agency develops the documents that will guide its enforcement and policy priorities over the next several years.


Memo
22-124
Tuesday, July 5, 2022

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


Memo
22-109
Tuesday, June 7, 2022

CWC’s written comments to the U.S. Citizenship and Immigration Services agency support its proposed changes to the Form I-9 that we believe will streamline the I-9 process as well as lessen paperwork burdens for employers.


Memo
22-082
Thursday, April 28, 2022

Our comment letter to OFCCP on the agency’s proposal to revise the 2020 Trump-era Enforcement Rule argues that rather than creating greater efficiency as OFCCP claims, the proposal will instead create additional delays in resolving agency allegations


Memo
22-081
Wednesday, April 27, 2022

MEMBER FEEDBACK REQUESTED. CWC has filed a comment letter with OFCCP in general support of the agency’s announced intent to extend its Functional Affirmative Action Program for another three years, while recommending some minor revisions that we beli


Memo
22-058
Monday, March 28, 2022

CWC’s comments to the Department of Agriculture urge the agency to withdraw a proposed rule that would allow USDA to deny government contracts to a company based on USDA’s assessment of the company’s labor law compliance.


Memo
22-003
Thursday, January 6, 2022

CWC has filed comments with U.S. Citizenship and Immigration Services, the agency that administers the I-9 verification process, urging USCIS to make permanent a current temporary policy that allows employers to conduct I-9 verifications remotely.


Memo
21-197
Thursday, October 7, 2021

The Federal Communications Commission is considering restoring an outdated workplace demographics reporting form similar to the EEO-1 that entities covered by the agency would have to file annually. In response to a request for public input, CWC has


Memo
21-172
Thursday, September 2, 2021

Our comments to the Labor Department regarding its proposed regulations to implement President Biden’s new Executive Order mandating a $15 an hour minimum wage on certain federal contracts urge consistency with regulations implementing a similar E.O.


Memo
21-169
Thursday, August 26, 2021

CWC has filed written comments with the Department of Labor opposing a new impractical test that DOL is proposing that will deter use of the so-called tip credit. Instead, our comments urge retention of a provision in last year’s revised tip regulati


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