CWC’s written comments to the Office of Management and Budget contend that burdensome changes that OFCCP is proposing to its compliance evaluation scheduling letter are neither warranted nor likely to increase agency efficiency.
Our written comments to the White House Office of Management and Budget are in response to preliminary proposals for revising the government’s race/ethnicity data collection and reporting standards, and explain how those changes would impact complian
CWC has filed comments with the White House Office of Management and Budget urging that agency to mandate sensible changes to OFCCP’s overly prescriptive Form CC-305 before giving OFCCP clearance to continue using the form for another three years.
CWC has filed written comments with the Federal Trade Commission asking the agency to withdraw a proposed rule that would ban the use of most non-compete agreements.
CWC has filed a comment letter with OFCCP expressing conditional support for the agency’s intent to implement a new “intake” form as part of OFCCP’s formal discrimination complaint process.
Our comments to the Equal Employment Opportunity Commission on its proposed 2023-2027 “Strategic Enforcement Plan” urge the agency to expedite compliance guidance on the recently enacted Pregnant Workers Fairness Act, while also offering several reco
Our comments to OFCCP in response to the agency’s announced intent to revise its compliance evaluation “Scheduling Letter” question whether a projected 35% increase in the burden imposed on federal contractors will make the audit process more “effici
CWC has filed written comments with OFCCP asking the agency to relax its rigid requirement that federal contractors must use the agency’s prescribed disability self-ID Form CC-305 despite ample evidence that the form is not effective in encouraging i
CWC has filed written comments with the Equal Employment Opportunity Commission in support of the agency’s announced intent to get approval from the White House Office of Management and Budget to continue using a slightly revised version of the EEO-1
Our written comments to the National Labor Relations Board argue that its proposal to abandon the balanced test for determining joint employment liability established by the Board in 2020 will unfairly skew the law to favor joint employer findings.
Our written comments to the Equal Employment Opportunity Commission on its draft “Strategic Plan” for 2022-2026 urge the agency to include metrics that will encourage quality charge investigations, with less emphasis on conducting resource-intensive
CWC’s written comments to the Department of Homeland Security argue that two years of positive experience by employers is more than enough to justify making permanent the current temporary policy of allowing I-9 verifications to be completed remotely
CWC’s written comments to the EEOC offer recommendations for issues to include as the agency develops the documents that will guide its enforcement and policy priorities over the next several years.
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
CWC’s written comments to the U.S. Citizenship and Immigration Services agency support its proposed changes to the Form I-9 that we believe will streamline the I-9 process as well as lessen paperwork burdens for employers.
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
MEMBER FEEDBACK REQUESTED. CWC has filed a comment letter with OFCCP in general support of the agency’s announced intent to extend its Functional Affirmative Action Program for another three years, while recommending some minor revisions that we beli
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.
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.
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
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.
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
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.
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.
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
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