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COMPLIANCE EVALUATIONS: FROM COURTESY LETTER TO SCHEDULING LETTER

April 23, 2013

Given the recent wave of OFCCP courtesy letters sent to federal contractors this month, we thought a short review of the process in moving from courtesy letter to scheduling letter would be of interest to readers of this blog. The OFCCP utilizes the...

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OFCCP AUDIT PUNCH LIST

April 23, 2013

Given the recent wave of OFCCP courtesy and scheduling letters, we thought that a blog on early preparations in the OFCCP audit process would be of interest. Recall that all federal contractors and subcontractors in receipt of a supply and service...

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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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RACE/ETHNICITY SUBGROUP ANALYSIS IN COMPENSATION ANALYSES: A CHANGE IN OFCCP PROTOCOL

April 09, 2013

OFCCP’s recent webinars on Directive 307 stated that compensation investigations will focus on individual race/ethnicity differences. If that is the case, a number of analytic questions require clarification.

  • Is the comparator group “White” or is...
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ISSUED COURTESY LETTERS TAKE PLACE OF CSAL

April 09, 2013

OFCCP recently issued a large wave of announcement letters, as noted in the blog last week (http://dciconsult.com/ofccp-sends-latest-round-of-csal-notices-to-contractor-establishments/). These letters are in the form of the same “courtesy” letters...

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WHAT CHANGED WITH DIRECTIVE 307?

April 09, 2013

OFCCP’s Directive 307 outlines policies for evaluating compensation data that depart in three primary ways from guidance presented in the rescinded Compensation Standards:

  • No requirement to construct and analyze compensation data by Similarly...
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OFCCP SENDS LATEST ROUND OF CSAL NOTICES TO CONTRACTOR ESTABLISHMENTS

April 01, 2013

OFCCP recently mailed its latest round of "courtesy" notices- the Corporate Scheduling Announcement Letter- to federal contractor establishments around the country. The form letters, dated March 27, 2013 and generically addressed to the "Human...

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HIGHLIGHTS FROM THE OFCCP PUBLIC BRIEFING

March 14, 2013

by Keli Wilson, Senior Consultant, DCI Consulting Group OFCCP officially rescinded the 2006 compensation standards and guidelines and released Directive 307 to replace previous guidance. Directive 307 describes the OFCCP procedures for compliance...

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BATTLE BETWEEN US SECURITY ASSOCIATES (USSA) AND OFCCP CONTINUES

February 14, 2013

by Art Gutman Ph.D., Professor, Florida Institute of TechnologyWe have twice reported on USSA’s battle with the OFCCP. In an Alert dated July 12, 2012, USSA filed an administrative complaint against the OFCCP on grounds that it violated it’s 4th...

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PAY EQUITY VOLUNTARY COMPLIANCE & MONITORING TIPS FROM OFCCP SENIOR STAFF

December 21, 2012

On Nov. 15, 2012, OFCCP’s Senior Program Advisor Pam Coukos and Mid-Atlantic Regional Director Michele Hodge presented at the Washington Metro Industry Liaison Group (WMILG) meeting. Baltimore District Director Tom Wells and Arlington Area Director...

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ENTERGY SERVICES 4TH AMENDMENT CHALLENGE TO OFCCP DENIED ON TECHNICAL GROUNDS

December 21, 2012

by Art Gutman Ph.D., Professor, Florida Institute of TechnologyWe’ve seen this play before. We reported on USSA’s 4th Amendment challenge in an Alert posted on July 17, 2012, and the results of that challenge in an Alert posted on 9/24/12. In that...

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OFCCP "Courtesy" Audit Letters to Replace CSAL?

November 20, 2012

Last week, the OFCCP sent out letters to federal contractors and subcontractors as “courtesy” notification of a supply and service compliance evaluation. Historically, the OFCCP sends a Corporate Scheduling Announcement Letter (CSAL) to the...

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