Wednesday, September 21, 2022

OFCCP has extended until October 19 the deadline for federal contractors to object to the agency’s release of their “Type 2” EEO-1 reports covering years 2016-2020. Our memo offers guidance as to how an objection might be crafted.

Tuesday, September 13, 2022

Our latest update of OFCCP financial settlements summarizes seven new settlements posted by the agency since our last update in May.

Tuesday, September 6, 2022

OFCCP has officially launched its new online Notification of Construction Contract Award Portal as the preferred, albeit optional, way for covered federal construction contractors to meet their obligation to notify the agency of certain subcontract a

Wednesday, August 24, 2022

OFCCP recently received an unprecedented FOIA request for all EEO-1 Type 2 reports held by the agency for filing years 2016 through 2020. OFCCP is giving affected federal contractors until September 19 to file objections, or will otherwise disclose t

Tuesday, August 23, 2022

WEB WORKSHOP SCHEDULED. OFCCP has issued a revised “compensation analysis” directive clarifying that agency compliance officers will not demand an analysis prepared under an applicable legal privilege as OFCCP claimed it had the right to do under the

Tuesday, August 16, 2022

MEMBER FEEDBACK REQUESTED. CWC is pleased to announce the launch of our new Integrating Compliance and Diversity, Equity & Inclusion memo series, leading with this introductory primer on the proper use of OFCCP-required “placement goals” for women an

Monday, August 1, 2022

In an announcement last week that also indicates its online AAP-VI Portal remains open despite a June 30 certification deadline, OFCCP has clarified that federal contractors that have not yet certified but have a pending Help Desk request made before

Tuesday, July 26, 2022

Exercising his authority pursuant to an order issued by his predecessor, Secretary of Labor Marty Walsh has overturned a ruling issued earlier this year by DOL’s Administrative Review Board that held that OFCCP had to use neutral criteria in scheduli

Monday, July 18, 2022

Our memo provides the latest information regarding the “HIRE” initiative, a joint effort between the EEOC and OFCCP launched last January that is designed to “identify strategies to remove unnecessary barriers to hiring and to promote effective, job-

Wednesday, July 13, 2022

While there has been no official announcement from OFCCP, the online Affirmative Action Program Verification Interface (AAP-VI) Contractor Portal is still open, despite a June 30 certification deadline. Our memo delves into the possible reasons why.

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

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

How-To Guides and Checklists
Tuesday, June 21, 2022

A checklist to assist in understanding and complying with OFCCP's annual AAP-VI certification requirement.

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.

Tuesday, June 14, 2022

The Government Accountability Office, the research arm of the U.S. Congress, has issued a report concluding that OFCCP needs to do more to assist federal contractors in meeting their compliance obligations under the Vietnam Era Veterans’ Readjustment

Wednesday, June 8, 2022

MEMBER FEEDBACK REQUESTED. OFCCP is seeking approval from the White House Office of Management and Budget to extend the Functional Affirmative Action Program option for another three years, a move that CWC supports.

How-To Guides and Checklists
Monday, June 6, 2022

A suite of resources to assist with planning, conducting, documenting and evaluation outreach efforts.

Thursday, June 2, 2022

In a new FAQ posted to its AAP-VI portal late last week, OFCCP has reversed course and is now saying that contractor establishments with fewer than 50 employees must be included if the contractor maintains an AAP for that site, even though not requir

Wednesday, June 1, 2022

Sometime in the next few months, OFCCP is expected to publish a formal proposal to modernize its “60-2” AAP regulations. Our memo proves a preview of some of the things it is likely to include.

Tuesday, May 31, 2022

Our most recent member roundtable featured a lively discussion among participants and CWC’s staff experts on the practical implications of OFCCP Director Jenny Yang’s new enforcement directive.

Thursday, May 26, 2022

As the June 30 deadline for data submissions under OFCCP’s new AAP-VI process approaches, the agency has rolled out a new bulk upload option that federal contractors with 100 or more establishments may find beneficial.

Monday, May 23, 2022

OFCCP has posted a new Corporate Scheduling Announcement List that flags some 400 federal contractor establishments for an upcoming compliance evaluation. Industries that increased hiring during the pandemic are prioritized for audits.

Wednesday, May 18, 2022

It’s been 16 months since OFCCP Director Jenny Yang assumed office, and during that time there have been some significant changes in key agency leadership positions. Our memo provides an update.

Monday, May 2, 2022

MEMBER FEEDBACK REQUESTED. CWC’s recent virtual member roundtable on OFCCP’s controversial pay equity audit directive involved a spirited discussion among the more than 50 member company participants. Our memo summarizes the highlights.

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

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