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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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WHEN GOOD FAITH IS NOT GOOD ENOUGH – LESSONS LEARNED 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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COULD YOU SEND US JOB DESCRIPTIONS FOR ALL 1,000 OF YOUR JOBS BY NEXT WEEK?

June 18, 2013

Because DCI has noticed an increase in the number of OFCCP requests for copies of job descriptions, we thought this might be a good time to discuss the importance of job descriptions. From an audit perspective, job descriptions can be a double-edged...

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An Imperfect Analysis: Promotions and Terminations

June 04, 2013

As a part of a complete proactive affirmative action program, it is a best practice to conduct disparity (a.k.a. adverse impact) analyses for promotions and terminations personnel activity. Conducting these analytics is not only important in regard...

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DIRECTIVE 307: MORE THOUGHTS ON PROACTIVE ANALYSES

June 04, 2013

This blog continues the ongoing discussion of the implications of Directive 307 on proactive pay equity analyses. As discussed in an earlier blog (http://dciconsult.com/playing-favorites-or-enforcing-systemic-equal-pay/), deciding which...

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MORE MUSINGS ON DIRECTIVE 307

June 03, 2013

Over the last few weeks, DCI staff members have written a number of blogs related to OFCCP’s pay equity directive. These blogs have focused on some of the challenges federal contractors will likely face when conducting proactive pay equity research...

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THE INCREASED LIKELIHOOD OF FALSE POSITIVES UNDER DIRECTIVE 307

May 21, 2013

In an ongoing series of blog posts, we will be dissecting portions of Directive 307 to highlight the potential pitfalls with the Directive’s prescriptions for conducting pay equity analyses. At issue this week is OFCCP’s oversight regarding the...

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PLAYING FAVORITES? OR ENFORCING SYSTEMIC EQUAL PAY?

May 21, 2013

When examining pay equity issues, the OFCCP and federal contractors historically took the approach of comparing Whites to an aggregate of all protected groups (total minorities). In the past few years, OFCCP has moved away from a White-Minority...

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Compliance Assistance: Have No Fear

May 21, 2013

OFCCP recently reiterated that Federal contractors or subcontractors seeking compliance assistance from the OFCCP can do so without fear of retaliation, in the form of a compliance evaluation, as expressed in the OFCCP’s Non-Retaliation Policy for...

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BERTUCCI CONTRACTING SETTLES RACE DISCRIMINATION CASE WITH OFCCP FOR $70,000

May 07, 2013

Bertucci provides flood control and restoration services and has received more than 80 million in federal contracts related disaster recovery efforts, most notably, in the wake of Hurricane Katrina in 2005 and the British Petroleum oil spill in...

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DISTRICT COURT AFFIRMS UPMC HOSPITALS ARE FEDERAL SUBCONTRACTORS

April 23, 2013

Three hospitals affiliated with the University of Pittsburgh Medical Center (UPMC) were considered subcontractors by District Court Judge Friedman on March 30, 2013. The case is UPMC Braddock v. Harris and includes UPMC Braddock, UPMC McKeesport and...

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