All Advocacy

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
22-047
Wednesday, March 9, 2022

CWC has filed a friend-of-the-court brief with the National Labor Relations Board arguing that the Board’s so-called “Boeing” standard that is used to balance employer and employee rights when determining whether an employer policy violates federal l


Memo
22-044
Monday, March 7, 2022

As the March 31 date allowing federal contractors to begin certifying their AAP obligations via OFCCP’s new Affirmative Action Program Verification Interface (AAP-VI) approaches, key questions about how the process works remain unanswered.


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The Federal Communications Commission is considering restoring an outdated workplace demographics reporting form similar to the EEO-1 that entities covered by the agency would have to file annually.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


Memo
21-109
Wednesday, May 26, 2021

CWC has filed comments with the Labor Department in support of keeping changes in the 2020 revisions to the “tip” regulations under the Fair Labor Standards Act that give greater recognition to good faith efforts by employers to comply.


Memo
21-105
Thursday, May 20, 2021

Federal paperwork requirements give the White House Office of Management and Budget the authority to instruct an agency to modify a proposed new information collection before approving the request.


Memo
21-094
Tuesday, May 4, 2021

CWC’s Mike Eastman was one of several invited witnesses asked by the EEOC to testify at a public hearing held last week on the civil rights impacts of the COVID-19 pandemic. Mike offered a number of recommendations on how the agency can provide helpf


Memo
21-083
Wednesday, April 21, 2021

CWC’s Mike Eastman has been invited to testify at an April 28 virtual public hearing being held by the Equal Employment Opportunity Commission on “the impact of the COVID-19 pandemic on workers, the difficulties faced by employers in navigating poten


Memo
21-081
Monday, April 19, 2021

CWC filed three comment letters with the Department of Labor last week once again providing sound reasons why the Biden Administration should allow important changes to the regulations implementing the Fair Labor Standards Act made by the prior admin


Memo
21-052
Monday, March 8, 2021

A new Labor Department regulation that would give employers helpful guidance on how to make employee/independent contractor classifications under the Fair Labor Standards Act has been put on hold by the Biden Administration. CWC urged DOL to let the


Memo
21-046
Tuesday, March 2, 2021

OFCCP wants to align the audit process for federal construction contractors more closely with the process used for supply and service contractors by using a new construction contractor scheduling letter. While the goal is laudable, OFCCP’s proposed l


Memo
21-045
Tuesday, March 2, 2021

The Department of Labor has delayed implementation of revised regulations issued during the previous administration that were designed to codify 2018 amendments to the Fair Labor Standards Act regarding how the law treats tipped employees. CWC filed


Memo
21-027
Wednesday, February 3, 2021

CWC’s comments to the White House Office of Management and Budget urge OMB to withhold approval of OFCCP’s proposed online AAP verification portal unless OFCCP makes changes to lessen the burden imposed on federal contractors.


Memo
21-018
Monday, January 25, 2021

CWC has filed written comments with the Labor Department’s Veterans’ Employment and Training Service component supporting its request to extend, without change, the mandated VETS-4212 report for another three years.


Memo
21-012
Monday, January 11, 2021

CWC has filed written comments with the Labor Department’s Veterans Employment and Training Service in support of that agency’s announced intent to extend the HIRE Vets Medallion Program for another three years. The HIRE Vets Medallion Program, which


Comments and Testimony
20-254
Monday, December 28, 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.


Comments and Testimony
20-242
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


Comments and Testimony
20-228
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


Comments and Testimony
20-224
Tuesday, November 10, 2020

CWC’s comments to the EEOC express strong support for the agency’s proposal to establish a set of standards to govern the agency’s conciliation procedures that will bring more consistency to the process and help minimize the potential for abuse.


Comments and Testimony
20-215
Wednesday, October 28, 2020

CWC has filed a comment letter with the Department of Labor strongly supporting the agency’s proposed interpretive rule for determining whether an individual is an employee or an independent contractor.


Comments and Testimony
20-190
Friday, September 25, 2020

Our comments to the Department of Labor on two separate “Requests for Information” seeking input on leave issues offer a number of recommendations for changes that we believe would help to mitigate some of the current compliance challenges faced by e


Briefs
20-145
Friday, July 24, 2020

Our brief submitted in support of the High Court taking up this case argues that the appeals court misinterpreted both the Federal Arbitration Act and Supreme Court precedent in ruling that an arbitrator could impose class arbitration even though the


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