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How Much Data is Enough When it Comes to Protected Veterans?

May 19, 2015

After release of the new VETS-4212 report requirements, federal contractors were instructed through OFCCP FAQs that they were not required to request individual protected veteran categories in their post-offer self-ID invitations. The OFCCP...

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OFCCP Pumps Gas on Steering: Comcast Signs Conciliation Agreement for Sex and Race Discrimination

May 15, 2015

On a news release dated April 30, 2015, OFCCP announced that Comcast Corporation’s Everett, WA location entered into a conciliation agreement to resolve allegations of sex and race discrimination. OFCCP’s review determined that Comcast steered 96...

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Sexual Orientation and Gender Identity Final Rule

March 03, 2015

The final rule for prohibiting discrimination based on sexual orientation and gender identity was published December 9, 2014. This rule becomes effective on April 8, 2015. Many contractors are wondering what actions need to be taken to comply with...

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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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