EO 11246

Wednesday, January 4, 2023

According to final Fiscal Year 2022 enforcement numbers available from the Department of Labor, there was a drop of more than 25% in audits completed by OFCCP and a more than 50% decrease in audits scheduled by the agency as compared to the previous

Tuesday, June 21, 2022

The Labor Department’s Administrative Review Board has reversed a ruling by an agency administrative law judge that found in favor of OFCCP, concluding that the ALJ used the wrong legal analyses when he held that a federal contractor committed hiring

Thursday, June 16, 2022

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.

Thursday, March 17, 2022

In the first major policy development since she assumed office, OFCCP Director Jenny Yang has issued a new directive instructing agency compliance officers to ask for a contractor’s pay analyses during a compliance evaluation, regardless of whether t

Monday, November 15, 2021

As expected, OFCCP has published a proposal to rescind regulations issued at the end of the Trump Administration that broadened the religious exemption under E.O. 11246.

Monday, November 8, 2021

In the last in our refresher series of memos on how OFCCP claims jurisdiction over a company that contracts or subcontracts with the federal government, we examine the minimum dollar thresholds.

Wednesday, October 13, 2021

Our latest memo on OFCCP jurisdictional issues looks at the agency’s use of a five-factor “single entity” test in determining whether a particular entity is subject to OFCCP requirements.

Tuesday, September 28, 2021

OFCCP has filed its first formal administrative enforcement action since the Biden Administration assumed office, in this case alleging hiring discrimination in entry level jobs by federal contractor ABM Janitorial Services.

Thursday, September 2, 2021

CWC is pleased to introduce a new member resource, our “Self-ID FAQ Resource,” that covers the most frequently asked questions about the “invitation to self-ID” requirements that our compliance experts typically receive.

Thursday, August 19, 2021

The White House Office of Management and Budget has given OFCCP the go-ahead to begin using a new compliance evaluation scheduling letter directed specifically to federal construction contractors and subcontractors.

Monday, August 16, 2021

A closer look at OFCCP enforcement data comparing the Obama and Trump Administrations may offer some insight as to what federal contractors can expect over the next several years.

Monday, August 2, 2021

As a follow-up to our recent memo on the “basics” of OFCCP’s jurisdictional coverage, this memo focuses on who qualifies as a covered OFCCP subcontractor.

Thursday, December 31, 2020

OFCCP is asking for approval from the government’s paperwork reduction watchdog to begin using two new desk audit scheduling letters, one focused on a federal contractor’s promotion practices and the other on a contractor’s accommodation practices.

Tuesday, December 15, 2020

OFCCP and the Oracle Corporation have reached a settlement that ends more than four years of administrative litigation brought by OFCCP against Oracle alleging compensation discrimination, as well as ends pending court litigation brought by the compa

Wednesday, December 9, 2020

OFCCP’s recently published FY 2020 enforcement numbers show a slight drop in audits closed during the previous year, but still an impressive amount in financial settlements. The numbers also confirm the increasing use of Early Resolution Conciliation

Comments and Testimony
Wednesday, December 9, 2020

Our comments to OFCCP in response to its Request for Information on training programs that might violate President Trump’s recently issued Executive Order 13950 stress both the commitment of CWC members to the principle and practice of equal employme

Thursday, December 3, 2020

This latest round of settlements, all announced within the last month, features a number of compensation discrimination cases and illustrates the increasing use of Early Resolution Conciliation Agreements (ERCAs) to resolve OFCCP’s allegations.

Thursday, November 19, 2020

OFCCP has announced its intent to extend for another three years the paperwork requirements that apply to construction contractors, and is seeking approval from the White House Office of Management and Budget (OMB) to proceed.

Comments and Testimony
Tuesday, November 17, 2020

CWC has filed written comments with OFCCP on that agency’s announced intent to implement a new online “Affirmative Action Program Verification Interface” that among other things would require federal contractors to certify annually that they have dev

Wednesday, November 11, 2020

OFCCP has issued a new and improved technical assistance guide for federal non-construction contractors. Our memo provides an overview, with more memos in the works that will focus in on some of the TAG’s nuances.

Wednesday, November 11, 2020

OFCCP has issued a new rule codifying into regulations the process used by the agency to notify a federal contractor of alleged material violations discovered during a compliance audit. As explained in our memo, the final rule helpfully addresses con

Thursday, November 5, 2020

The EEOC has approved a revised Memorandum of Understanding with OFCCP and the Justice Department aimed at improving interagency coordination efforts regarding enforcement of the federal civil rights laws.

Thursday, October 29, 2020

OFCCP Director Craig Leen was the featured speaker earlier this week in one of CWC’s ongoing virtual Compliance, Diversity & Inclusion Roundtables being held in lieu of our annual Compliance Conference because of the Coronavirus pandemic. He discusse

Monday, October 26, 2020

CWC’s round-up of OFCCP financial settlements shows a lot of activity since our last update in September. Consistent with a trend we’ve seen over the past year, this latest batch includes six Early Resolution Conciliation Agreements (ERCAs).

Wednesday, October 21, 2020

OFCCP Director Craig Leen has issued a National Interest Exemption that temporarily relieves federal contractors providing Hurricane Delta relief from having to prepare a written AAP. This is the fifteenth NIE issued by OFCCP during the Trump Adminis

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