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SEX DISCRIMINATION NPRM: IS MANHANDLING JOB TITLES NECESSARY TO COMPLY?

February 13, 2015

OFCCP’s notice of proposed rulemaking (NPRM) addressing Discrimination on the Basis of Sex is lacking clarity on several points and seems to contradict itself as well. This blog post focuses on the proposed changes to part 60-20.2 General...

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"Distinguishing On The Basis Of Sex...": Will the Revised Sex Discrimination Regulations Impact Our Good Faith and Outreach Efforts For Women?

February 10, 2015

As proposed in the Notice of Proposed Rulemaking (NPRM) for the Sex Discrimination Guidelines, sections 60-20.2(b)(7) and 60-20.2(b)(8) of the revised regulations will seem to limit the federal contractor’s ability to recruit and engage potential...

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Submitting an Updated Plan in an OFCCP Desk Audit: What is the Temporal Scope?

February 03, 2015

In the wake of the new scheduling letter (released in October 2014) and the ensuing OFCCP audit activity, contractors are taking steps to prepare for possible audits. The contractor community has raised a number of questions and concerns in response...

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1:1 Hiring Ratios - Are They So Bad?

February 02, 2015

DCI has noted a recent trend among some compliance officers that are alleging that a 1:1 applicant to hire ratio is a “per se” violation of the regulations. If this was true, virtually all contractors would be in violation of the regulations. It is...

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Proposed Rulemaking for Revisions to Sex Discrimination Guidelines Released

January 28, 2015

Today, January, 28, 2015, OFCCP released the Notice of Proposed Rulemaking (NPRM) for the long awaited revisions to the Sex Discrimination Guidelines (RIN 1250-AA05). The proposed changes are presented to align the guidance with laws, court...

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OFCCP Releases New FAQs On The Revised Scheduling Letter

December 10, 2014

OFCCP has just released three new FAQs regarding the partial year data and analysis required for the Section 503 and VEVRAA items in the revised scheduling letter.  As presented in a previous blog, FAQs regarding how to submit compensation data under...

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OFCCP TO RELEASE FINAL RULE ON GENDER IDENTITY DISCRIMINATION

December 02, 2014

The OFCCP reported it will release final rules on, among other things, gender identity and, more generally, sex discrimination which, by its own admission, are 30 years old and out of date (see the formal notice). The initial directive on gender...

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OFCCP'S SEX DISCRIMINATION GUIDELINES NPRM LANDED AT OMB ON FRIDAY

November 24, 2014

OFCCP submitted a Notice of Proposed Rulemaking (NPRM) to OMB on Friday, November 21. Once OMB reviews, it will be placed on the federal register for notice and comment. Contractors should be on the lookout for the proposed rule and provide comments...

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Newly Released Compensation Guidance: Scheduling Letter Itemized Listing

November 18, 2014

A month and a half has now passed since the release of the new scheduling letter, and the OFCCP has finally provided federal contractors with some guidance on submission of employee compensation data under ‘Item 19’ of the itemized listing. The...

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NEW SOUTHEAST REGIONAL DIRECTOR AND CORPORATE SCHEDULING ANNOUNCEMENT LETTERS

November 14, 2014

The OFCCP has selected a new regional director for the Southeast Regional Office. Sam Maiden will be the new director of OFCCP’s Southeast Regional Office starting on December 14. Sam will lead a team of 108 staff working in the regional...

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FAQ Clarifies Storage Options For Disability Self-Identification

November 04, 2014

OFCCP has posted a new FAQ detailing the acceptable options for a contractor in documenting the voluntary invitation to self-identify as an individual with a disability. Based on contractors’ varying technology capabilities and practices, the FAQ...

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New Guidance on Job Listing Options for “Remote Jobs”

October 30, 2014

The requirement to list job openings with the appropriate employment service delivery system (ESDS) where the opening occurs is not new. However, contractors have questioned how to interpret and comply with this requirement for flexible “remote...

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