Archive for the ‘Affirmative Action’ Category

Joint Employment and Federal Contractors

Posted by | Filed under Affirmative Action, Compliance, HR | Aug 1, 2016 | Tags: , , , | No Comments

Joint employment, and the issues it brings, has been around for a while. But with the NLRB decision last year in Browning Ferris II, the scope of what it means to be a joint employer has broadened. And while there is no regulation spelling out this new standard, the DOL and OFCCP are jumping on […]

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OFCCP’s LGBT Executive Order and its impact

Executive Order 13672 Highlights: LGBT non discrimination E.O. 13672 went into the Federal Register Dec. 9, 2014 and will be effective April 8, 2015 Any place your organization displays the entire list of protected classes, gender identity and sexual orientation must be added EO Clause for contracts and sub contracts should be amended, along with Ad […]

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Key Changes to OFCCP Scheduling Letter

Audit requests in 2015 will look different and ask for more information, as the scheduling letter has changed. Key changes: Personnel activity (hires, promotions, terms, applicant flow) can be provided either by job group OR job title but if submitted by title, you must also include department and job group (we’ve always provided by job […]

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3 Things to do NOW to prepare for the new OFCCP regulations

Effective 3/24/14 the OFCCP’s regulation will significantly change. Primarily, there will be targets for Veterans and Disabled and additional reporting, record keeping and notices. The regulations will require that you survey your employee population every 5 years (with interim reminders) for disability status and has released the form that should be used: http://www.dol.gov/ofccp/regs/compliance/sec503/SelfId_Disability_CC_305_012214_JRF_QA_508c.pdf So what […]

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10 things to do NOW to stay compliant with OFCCP regs

Here are our 10 tips for staying compliant with OFCCP regulations:    1. Talk to your business development department, procurement department or other key sales people in your organization to determine if you are a federal government contractor or subcontractor.  We’re encountering many situations where an audit letter was the first notice for HR or […]

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2011 OFCCP review

WOW! 2012 was an interesting year on the OFCCP front.  Here’s what we experienced: As advertised, we noticed a decline in the number of audits but the audits we assisted with were INTENSE. The Chicago office experienced a backlog resulting in rescinded audits and the movement of cases in that office to other offices. We […]

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Addressing the 13%

The US Department of Labor states that the unemployment rate for the disabled is 13% – 1.5x the rate of those without disabilities.  In order to address that high rate, the OFCCP is proposing a 7% disability hiring goal for Affirmative Action employers – strengthening the Rehabilitation Act. Visit the federal e-rulemaking portal at http://www.regulations.gov […]

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The best defense is a good offense

In football and human resources (still hurting from that Cowboys loss last night!), having an offensive strategy is imperative, particularly in the compliance area.  Many companies receive their affirmative action plans, give them a quick glance then stick them on a shelf just praying that this is a year they won’t be audited. We’re advocating […]

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The Times They are A Changing

The OFCCP – Changes you Can’t Believe! The shift in policies of the Department of Labor under Hilda Solis’s leadership has finally trickled down into the Office of Federal Contract Compliance (OFCCP).  In December 2010, the agency scrapped the Bush administration’s Active Case Management Program and adopted an Active Case Enforcement (ACE) Program.  As a […]

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One is the loneliest number…

Now that your EEO-1 and Vets-100 reports are filed, have you taken the time to analyze the data?  These pesky reports are often an exercise in frustration but are used by both the EEOC and the OFCCP for trending, audit selection and data analyses.  We assisted some clients with their reporting this year (the old […]

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