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David Cohen, M.S.

David Cohen, M.S.
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OFCCP's Scheduling Letter to be Approved and Released September 30th

September 29, 2014

In 2011, the OFCCP proposed major changes to the current scheduling letter and itemized listing. After three years, the OFCCP has received approval from OMB to make some of the changes that were requested. These changes (especially the change to...

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Buckle Up: OFCCP Continues to Press the Gas on Steering

June 19, 2014

As previously discussed in this blog, a recent trend in OFCCP audits is the focus on job assignment and/or steering. What is steering? Steering refers to a company practice where members of a protected class are disproportionately “steered” into a...

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OFCCP Financial Settlements: FY2013 Trends

October 29, 2013

The US Department of Labor makes enforcement data collected by the OFCCP searchable to the public. Although the recent government shutdown has prevented the agency from updating the database to include settlements through the end of the federal...

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OFCCP Releases Updated Federal Contract Compliance Manual (FCCM)

August 23, 2013

After years in the making and much anticipation, the OFCCP released the Federal Contract Compliance Manual (FCCM) to the public today. It is our understanding that the FCCM was released to OFCCP field staff for some time now and the national office...

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OFCCP SUBMITS 503 REGULATIONS TODAY

July 31, 2013
Shortly after submitting the 4212 regulations, the OFCCP has submitted the 503 regulations to the Office of Management and Budget (OMB) today in final form. OMB has at least 60 days to review the regulations. This does not mean the regulations are...
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OFCCP Submits 4212 Regulations to OMB

July 31, 2013
OFCCP has submitted the 4212 regulations to the Office of Management and Budget (OMB) today in final form. OMB has at least 60 days to review the regulations. This does not mean the regulations are final and in place ---- OMB can now either approve...
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OFCCP Releases Directive 310 Providing Guidance on Back Pay Calculations

July 25, 2013
OFCCP has released Directive 310 to provide guidance on calculating back pay as a part of make whole relief for victims of employment discrimination when using formula or individual relief. DCI is currently reviewing this new directive and will...
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UPDATE TO OFCCP’s ONLINE CSAL LIST

July 19, 2013

In yesterday’s client alert, we announced that OFCCP has released its CSAL online. However, an official with OFCCP has stated that the release of this list on its website was a “technical snafu” and was not intended to be released. The official...

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When Good Faith is Not Good Enough – Lessons Leanred From OFCCP Audits

July 09, 2013

In Fiscal Year 2012, 30% of all OFCCP compliance evaluations closed with a technical conciliation agreement. Compare this number to FY 2004, where 5% of all compliance reviews closed with a technical conciliation agreement. A technical conciliation...

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Outreach to Veterans II: Become A Champion

June 18, 2013

In our first Outreach to Veterans blog, we focused on developing a veteran recruitment strategy that considered resources available to you and how to maximize them. In addition, tips and resources were provided to ramp up your outreach efforts. To...

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What is the Status of Proposed Veteran (4212) and Disability (503) Regulations?

May 07, 2013

Based upon the FY 2013 Budget Request to Congress, OFCCP planned to release in final form the Veterans and Disabilities regulations sometime in April of 2013. However, those regulations are still at OFCCP going through “revisions” and have not been...

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Outreach to Veterans: Are You Meeting Your Obligations?

April 09, 2013

Federal contractors and subcontractors that are covered under the Vietnam Era Veteran’s Readjustment Act of 1974 (VEVRAA) are required to take affirmative action in employing and advancing covered veterans. In practice, this means that contractors...

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