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Recent OFCCP Audit Trends: Steering Cases

December 05, 2013
In light of the recent settlement with G&K, DCI is noting trends in current OFCCP audits related to personnel steering issues. G&K Services Co. settled claims of hiring discrimination with the OFCCP earlier this month, including $265,983 in back pay...
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503 and VEVRAA Audit Activity: New Regulations Overshadowing Current Regulations?

December 05, 2013
With the new 503 and VEVRAA regulations looming around the corner, we have recently experienced audits with an increased interest in the ‘raw’ data behind federal contractor’s outreach efforts. In fact, data requests are going beyond the narrative...
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Will Your Method of Identifying Underutilization be Accepted by the OFCCP?

October 29, 2013

As shared in an earlier blog, the OFCCP released an updated Federal Contractor Compliance Manual (FCCM) in August 2013. The FCCM does not create new law, but is the operating manual that compliance officers will use throughout the compliance...

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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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Choose Your Own Comparator: The Importance of Race Coding Strategy in Compensation Equity Analyses

October 01, 2013

In a prior blog post, we indicated that OFCCP has taken a position that the specific strategy for dummy coding races in a regression analysis does not matter. Specifically, they have argued that the group that one chooses as the referent group is...

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A SPECULATIVE NOTE ON WHAT THE FUTURE MAY BRING

September 24, 2013

Recent DCI blogs have summarized high-level themes from the new 503 and VEVRAA regulations. One theme relates to the new analytics that may be required by the final regulations. The new regulations provide for a (1) protected veteran benchmark...

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Implications of VF Jeanswear Case on Race Comparison Groups

September 04, 2013

In a follow-up to our August 7th blog on the ALJ ruling in the OFCCP v VF Jeanswear Limited case, we’d like to reiterate the importance of this case for contractors covered by EO 11246. In the last 5 or so years, some regions of OFCCP have moved...

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DCI Staff Attend 31st ILG Annual Conference Held in Indianapolis

August 14, 2013

The 31st Annual National Conference for the Industry Liaison Group (ILG) was held July 30 – August 2, 2013 in Indianapolis, IN. This annual conference brings together members of the federal contracting community to discuss affirmative action and...

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INITIAL EFFECTS OF DIRECTIVE 307 DURING OFCCP AUDITS

July 23, 2013

In light of the recent OFCCP Directive 307, DCI has noted trends during audit situations related to how OFCCP staff are interpreting and enforcing the directive.

In some Regional and District Offices, there are circumstances where compliance...

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OFCCP Settles With TUFTS Associated Health Plans on Race-Based Claims of Discrimination and Retaliation

July 19, 2013

In a press release dated July 17, 2013, the OFCCP announced that Tufts Associated Health Plans has agreed to a $372,739 settlement related to charges of race-based discrimination in termination and retaliation. The text of the settlement may be...

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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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OFCCP Begins Posting CSAL Notices Online

July 18, 2013
At last year's Industry Liaison Group (ILG) National Conference in Hawaii, OFCCP Deputy Director Tom Dowd announced that the agency would begin posting Corporate Scheduling Announcement Letters (CSAL) on the OFCCP website. At the time, many in the...
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