by David Cohen, President and Patricia Schaeffer-Vice President Regulatory Affairs
Small single establishment companies, which may not have received much scrutiny from OFCCP in the past, may now find themselves receiving scheduling letters from the agency for compliance reviews.
According to a discussion with a senior OFCCP official, the successful implementation of the OFCCP’s “Contracts First Initiative” is most likely responsible for the increase in scheduling letters to single establishment companies. The OFCCP’s Contracts First is designed in part to identify establishments that do not identify themselves as federal contractors on the EEO-1 form. OFCCP currently uses several different comprehensive databases to cross-check companies that are, in fact, federal contractors.
Contracts First has also been coupled with the agency’s Federal Contractor Selection System (FCSS), a mathematical model that ranks federal contractor establishments based on an indicator of potential workplace discrimination. This model compares differences in each establishment’s workforce profile to census data on local labor markets and the workforce profile of establishments in the same industry.
