DCI Consulting Blog

Over the past six months, DCI has continued to monitor OFCCP enforcement trends and priorities regarding compliance evaluations in FY 2016. In our 2015 blog we noted a reduction in the number of new audit scheduling letters received throughout 2015,...

In response to the call for public comments, The Institute for Workplace Equality submitted comments regarding the EEOC’s proposed update to the EEO-1 annual report. The OFCCP Institute’s feedback addresses concerns about the burden estimate and pay...

On March 15, 2016, The Wall Street Journal released an article focusing on the results of pay discrimination investigations carried out by the Office of Federal Contracts Compliance Programs (OFCCP) through their standard compliance review process....

Recently DCI has noted a new trend in OFCCP enforcement of alleged base pay discrimination. Specifically, upon identifying statistical disparities in base pay, OFCCP has proceeded to enforcement under a theory of disparate impact rather than the...

Federal contractors doing business with the federal government must comply with the regulations enforced by OFCCP and during a compliance evaluation, they must submit all items on the scheduling letter. However, some of the proactive analyses that...

Since the release of OFCCP’s FY 2017 budget justification on February 8, 2016, the federal contractor community has been buzzing, as OFCCP’s requests shed light on the agency’s enforcement priorities for the near future. Given the current political...

The Scheduling Letter and Itemized Listing, reviewed and approved by the Office of Management and Budget (OMB), set the framework for what data are required to submit in a compliance review. Specifically, item 18 in the Itemized Listing requires...

Given the high prevalence of data security breaches and identity theft today, organizational leadership should be making the protection of their consumers’ and their employees’ confidential information a high priority. It is no surprise that federal...

As contractors prepare for 2016, we want to share some reminders on what to be prepared for in the New Year with OFCCP and EEO compliance. 

1.)    First full year of 503/VEVRAA analytics under Subpart C

Contractors were required to come into...

The OFCCP Institute (“The Institute”) recently submitted comments in response to OFCCP’s Proposed Renewal of Information Collection Requirements, published on October 29, 2015, which describes proposed changes to the Scheduling Letter and Itemized...

If the recently passed federal FY2016 budget is any indication, Congress is not pleased with the current direction of OFCCP. The first indication of this displeasure is the actual budget appropriation for OFCCP. OFCCP asked for a $7.2 million...

With OFCCP regularly requesting multiple forms of compensation during compliance audits, we revisit the difference between EEO compliance evaluations of base pay versus other compensation metrics. An individual’s base pay is a function of many...