In Part I we gained an overview of the changes to the OFCCP’s Scheduling Letter and the Itemized List. In this part we will discuss the changes related to compensation practices, and their likely impact, as they appear to be the changes posing the biggest concerns for contractors. A. Compensation Data: The new Item 19…
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More than three years after it promised federal contractors a new Scheduling Letter and Itemized Listing, the OFCCP finally delivered on October 1. The OFCCP sends a Scheduling Letter to contractors at the beginning of an audit to request copies of the contractor’s Affirmative Action Plan(s) and other data within 30 days of the contractor’s…
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The OFCCP has announced that it intends to update affirmative action rules for construction contractors. The goal was to have proposed rules by April 2014. Although it has not met that goal, to all of you construction contractors out there, beware! The OFCCP has not forgotten about you! Its September 16 announcement of a settlement…
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A. Civil rights unrest flashback: For many, the uproar over the Ferguson police response to protests in the days following Michael Brown’s killing brought about flashbacks of the struggle for racial justice, which resulted in Civil Rights Act of 1964. Prior to the Civil Rights Act decades of racial segregation mandated by the Jim Crow…
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It’s really happening. The OFCCP is now delivering a key item on its list of coming attractions with its Notice of Proposed Rulemaking (NPRM) regarding collection of summary data on federal contractors’ and subcontractors’ compensation practices. The OFCCP would use the information in the reports to compile and publish aggregate industry compensation data and standards….
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