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UPDATE TO OFCCP’s ONLINE CSAL LIST

July 19, 2013

In yesterday’s client alert, we announced that OFCCP has released its CSAL online. However, an official with OFCCP has stated that the release of this list on its website was a “technical snafu” and was not intended to be released. The official...

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OFCCP Begins Posting CSAL Notices Online

July 18, 2013
At last year's Industry Liaison Group (ILG) National Conference in Hawaii, OFCCP Deputy Director Tom Dowd announced that the agency would begin posting Corporate Scheduling Announcement Letters (CSAL) on the OFCCP website. At the time, many in the...
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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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Interpreting Section 503 of the Rehabilitation Act

July 09, 2013
The federal contractor community has been anticipating a 2013 final rule updating affirmative action and nondiscrimination obligations regarding individuals with disabilities. However, it may also be useful to think about what is currently required...
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When Good Faith is Not Good Enough – Lessons Leanred From OFCCP Audits

July 09, 2013

In Fiscal Year 2012, 30% of all OFCCP compliance evaluations closed with a technical conciliation agreement. Compare this number to FY 2004, where 5% of all compliance reviews closed with a technical conciliation agreement. A technical conciliation...

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Could you send us job descriptions for all 1,000 of your jobs by next week?

June 18, 2013

Because DCI has noticed an increase in the number of OFCCP requests for copies of job descriptions, we thought this might be a good time to discuss the importance of job descriptions. From an audit perspective, job descriptions can be a double-edged...

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An Imperfect Analysis: Promotions and Terminations

June 04, 2013

As a part of a complete proactive affirmative action program, it is a best practice to conduct disparity (a.k.a. adverse impact) analyses for promotions and terminations personnel activity. Conducting these analytics is not only important in regard...

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Directive 307: More Thoughts on Proactive Analyses

June 04, 2013

This blog continues the ongoing discussion of the implications of Directive 307 on proactive pay equity analyses. As discussed in an earlier blog, deciding which racial/ethnic subgroups to compare in a pay equity analysis and at which unit of...

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More Musings on Directive 307

June 03, 2013

Over the last few weeks, DCI staff members have written a number of blogs related to OFCCP’s pay equity directive. These blogs have focused on some of the challenges federal contractors will likely face when conducting proactive pay equity research...

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2010 CENSUS DATA: AN UPDATE FOR FEDERAL CONTRACTORS

May 21, 2013

Join us for a webinar to discuss OFCCP’s recent notice to federal contractors on the use of the 2006-2010 American Community Survey (ACS) EEO Tabulation in the development of their annual AAPs. OFCCP has informed federal contractors that the date...

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THE INCREASED LIKELIHOOD OF FALSE POSITIVES UNDER DIRECTIVE 307

May 21, 2013

In an ongoing series of blog posts, we will be dissecting portions of Directive 307 to highlight the potential pitfalls with the Directive’s prescriptions for conducting pay equity analyses. At issue this week is OFCCP’s oversight regarding the...

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Playing Favorites? or Enforcing Systemic Equal Pay?

May 21, 2013

When examining pay equity issues, the OFCCP and federal contractors historically took the approach of comparing Whites to an aggregate of all protected groups (total minorities). In the past few years, OFCCP has moved away from a White-Minority...

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