Welcome to the DCI Consulting Blog


March 03, 2014

During a recent audit experience, a compliance officer insisted that the workforce analysis was incorrect because a supervisor (including name) was not listed for each department. We thought it would be a great time to provide a quick refresher...

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February 11, 2014

Since OFCCP’s compensation Directive 307, federal contractors are experiencing more intense scrutiny of their compensation systems during OFCCP compliance reviews. A recent trend among compliance officers across regions is to ask contractors to...

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Use of 2010 Census Data in 2014

December 17, 2013

Earlier this year, OFCCP informed the contractor community that the 2006-2010 American Community Survey (ACS) EEO Tabulation must be used in affirmative action plans commencing on or after January 1, 2014. The EEO Tabulation was released by the ...

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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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Status Update on VETS-100a and EEO-1 Filings

October 22, 2013

Now that federal employees are back to work after the government shutdown, what is the status of the EEO-1 and VETS-100A annual required filings? The standard EEO-1 reporting deadline (September 30th) passed prior to the shutdown. For contractors...

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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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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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Subgroup Analyses Under Directive 307: Awaiting an Update From OFCCP

July 23, 2013

Since its release in February 2013, Directive 307 has certainly been on the mind of federal contractors. This blog has covered a number of issues related to Directive 307 that may make proactive analyses of pay equity complicated. One such issue...

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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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Am I Underutilized?

July 09, 2013

Federal contractors covered under Executive Order (EO) 11246 are required to conduct several quantitative analyses as part of their affirmative action program (AAP). To determine in which job groups minorities and females are underutilized, 41...

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