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Please Refer to the CBA: Recent OFCCP Audits Focus on Pay Practices for Bargaining Employees

September 16, 2014

This is the second blog in our series on Steering and OFCCP enforcement.  As discussed in our first blog of the series, OFCCP has focused on investigating compensation as a byproduct of steering during compensation reviews. Toward that end, DCI has...

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Record Keeping Renewal for Construction Contractors

September 16, 2014

OFCCP is seeking public comments on its proposed information collection request (ICR) to renew recordkeeping and reporting requirements for construction contractors. The ICR was published in the Federal Register on September 2nd.

This proposal...

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Can You Juggle? Equal Pay Report, OFCCP FAQS Create Multiple 'Employee' Definitions For Contractors

September 15, 2014

On August 6, 2014, OFCCP issued a Notice of Proposed Rulemaking (NPRM) which will require covered Federal contractors and subcontractors with more than 100 employees to submit an Equal Pay Report (EPR) regarding employee compensation. As explained...

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Proposed Revisions to Required Disability Self-ID Forms: New Languages and Drop-Down Response

September 10, 2014

On September 8, 2014, the Office of Information and Regulatory Affairs (OIRA) in the Office of Management and Budget (OMB) received a submission from OFCCP seeking approval to implement two non-material changes to the Voluntary Self-Identification...

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Hold the Brakes: It's Time to Suspend Steering!

August 25, 2014

Steering is the policy or practice of directing applicants or employees to certain jobs (or departments) based on stereotypes and biases. The result of steering is a concentration of one group (e.g. women and minorities) into certain jobs (or...

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OFCCP COURTESY NOTIFICATIONS - FY 2014 SECOND RELEASE

August 11, 2014

On July 16, 2014, the second release of the FY 2014 Corporate Scheduling Announcement Letters (CSALs) was sent out by OFCCP. These letters serve as an advanced courtesy notification to federal contractors and subcontractors that one or more of their...

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OFCCP'S New FAQS: Disability Utilization Goals Gone Wilder

July 08, 2014

During a recent release of the revised Section 503 and VEVRAA FAQs on the OFCCP website, the agency outlined their interpretation of how non-responses to the invitation to self-identify as an individual with a disability should be treated in an...

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Can Employers Override Protected-Veteran Status Post-Offer?

July 07, 2014

Among the new FAQs released on June 18, 2014, OFCCP responded to the following contractor question:

“If an individual self-identifies as a protected veteran at the pre-offer stage of the application process, but does not self-identify again at the...

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Once More Unto The Breach: What is a Hiring Benchmark?

July 02, 2014

OFCCP recently released a series of new FAQs relating to the revised 503 and VEVRAA regulations. This blog will address the FAQ addressing the definition of “hires” to be used when assessing compliance with the hiring benchmark under VEVRAA. In two...

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PREFERENTIAL HIRING BASED ON DISABILITY STATUS MAY BE A RISKY MOVE

June 27, 2014

On June 18, OFCCP updated the FAQs for Section 503 of the Rehabilitation Act (Section 503). One notable addition pertains to preferential hiring of individuals with disabilities:

Under the new regulations, must a contractor hire an individual with a...

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New VEVRAA and Section 503 FAQS: Jobs Filled

June 25, 2014

The Department of Labor’s OFCCP released six new FAQs covering portions of the VEVRAA and Section 503 regulations.  This blog addresses the new guidance for determining the number of "jobs filled" for an affirmative action plan. As a reminder, jobs...

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DCI Announces "Webinar Wednesdays" to Begin July 9

June 23, 2014

DCI is gearing up to host a series of complimentary webinars to provide the federal contractor community with the most up-to-date guidance and tips for ensuring EEO compliance. Beginning July 9 through November, register for our Webinar Wednesdays...

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