This afternoon, Wednesday, September 23, OFCCP published new landing pages for the upcoming promotions and accommodations focused reviews. Both types of focused reviews are new to the 2020 CSAL; for more information, please refer to our previous blog posts on the CSAL and its subsequent revision.
These landing pages have been highly anticipated in the contractor community. Up until this point, there had been limited guidance from the agency on what contractors could expect during these new types of reviews. The recently published pages will serve as central resource banks for contractors selected for these new reviews as they prepare.
Both landing pages include a brief introduction on the purpose and goals of the focused reviews, supplemented with information more specific to each type of review. Quick links are also provided to relevant placeholders, with a few placeholders for items such as Best Practices and Resources (denoted as “coming soon”).
The accommodations focused reviews will consist of a document review with particular emphasis on accommodation denials, as well as interviews with managers responsible for communicating with applicants and employees on accommodation requests. The agency clarified that both religious and disability accommodations will be reviewed.
Similar to Corporate Management Compliance Evaluations (CMCEs), the promotions reviews will be focused on potential “glass ceilings.” Additionally, in these reviews OFCCP notes that it will seek to examine the intersection between race and gender. The reviews will include an examination of contractor policies and procedures, employee personnel files, as well as personnel data tracking promotion decisions. In addition, contractors can anticipate interviews with managers responsible for promotion decisions, and if applicable, with affected employees.
It does not appear that OFCCP will be developing a scheduling letter and itemized listing tailored to the promotion and accommodation reviews as they did with the Section 503 and VEVRAA focused reviews and will instead used the standard letter and itemized listing.
DCI will continue to post updates on the focused reviews here on our blog.
By Lily Kerr, HR Analyst, and Amanda Bowman, Associate Principal Consultant at DCI Consulting Group