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  OFCCP FAQ Series: Federal Contractor Selection System (FCSS)
by Carla Irwin - Dec, 2011
Beginning in January 2011, OFCCP implemented its new audit strategy that moved the philosophy of compliance evaluations from management to enforcement. Director Shiu discontinued the previous compliance evaluation strategy of Active Case Management (ACM) and rang in the new year with a new directive, Active Case Enforcement (ACE). The switch to ACE is part of the OFCCP’s plan to continually increase efforts to enforce com...
 
  OFCCP FAQ Series: Functional Affirmative Action Program (FAAP)
by Carla Irwin - Aug, 2011
In June, the OFCCP released a new directive outlining updates to the FAAP process. According to Director Patricia Shiu, “the FAAP is back and is better than before.” Below are excerpts from the OFCCP’s Functional Affirmative Action Program (FAAP) FAQs. Click here to read the full version. What is a Functional Affirmative Action Program? Each covered non-construction contractor must develop and maintain an af...
 
  OFCCP v. Frito-Lay – Ruling Limiting Scope
by Carla Irwin - May, 2011
Federal contractors, open a bag of Frito-Lays in honor of their win against the OFCCP. The facts are as follows: On July 13, 2007, the OFCCP sent Frito-Lay a Scheduling Letter to its Dallas Baked Snack facility. As many of you know Item 10 of the Scheduling Letter requests “Data on your employment activity (applicants, hires, promotions and terminations) for the preceding AAP year and, if you are six months or more into yo...
 
  Affirmative Action Plan Implementation: Additional Required Elements
by Carla Irwin - May, 2011
For those of you with calendar year AAPs, this month begins the mad dash to just get your AAPs completed, but I urge you to pause and take stock of the non-statistical elements of your AAP. The OFCCP has sent out the Corporate Scheduling Announcement Letters (CSALs) and this year you will see audits handled alittle differently. Active case management has been discontinued which means focusing solely on systemic discriminatio...
 
  DOL Strategic Plan FY 2011-2016 and the Role of the OFCCP
by Carla Irwin - May, 2011
The Department of Labor (DOL) recently released its Strategic Plan for Fiscal Years 2011-2016. The plan is about workers, accountability and doing what works. The Plan includes the five following goals: 1.Prepare workers for good jobs and ensure fair compensation 2.Ensure workplaces are safe and healthy 3.Assure fair and high quality worklife environments 4.Secure health benefits, and for those not working, provide inco...
 
  OFCCP Deputy Director Statement to Congress: Priorities & Focus on Veterans
by Carla Irwin - May, 2011
On September 29th, OFCCP Deputy Director Les Jin testified before a subcommittee focusing on federal contractors and subcontractors compliance and OFCCP enforcement of veterans regulations. The testimony began with an outline of the OFCCP’s three priorities: 1. Strengthening enforcement, “Director Shiu has worked with our Regional Directors to institute a new protocol that requires OFCCP compliance officers to go on-...
 
  OFCCP Proposes Revisions to Scheduling Letter
by Carla Irwin - May, 2011
On May 12th, OFCCP published in the Federal Register its proposed changes to the Scheduling Letter and Itemized Listing. Below is the OFCCP’s description and justification of the proposed changes: “OFCCP has revised the Scheduling Letter and its Itemized Listing. These revisions will reduce overall burden hours on contractors and enhance OFCCP’s desk audit and data analysis abilities. The revisions in the body of the S...
 
  OFCCP Regulatory Agenda Webchat Highlights
by Carla Irwin - May, 2011
In December 2010, the OFCCP’s Fall 2010 regulatory agenda was published in the Federal Register and in an effort to promote contractor feedback, Patricia Shiu hosted a live webchat Friday, January 7th, 2011. Below are a few highlights. Compensation Data Collection Tool/Rescission of 2006 Compensation Guidance •OFCCP will continue to follow Title VII principles in investigating and analyzing compensation discrimination •O...
 
  This Place Changes Everything
by Carla Irwin - May, 2011
I just got back from the USBLN 2010 Conference – Aligning Disability with the Bottom Line: Talent, Market Share and Supplier Diversity. I have been to many conferences over the years, but this will be remembered as the one that changed everything for me. I went into this conference with the goal of gaining new insight and knowledge about outreach programs and support for people with disabilities. I did this with the intent...
 
  OFCCP Proposes New Rule To Strengthen Affirmative Action Requirements
by Carla Irwin - May, 2011
US Labor Department proposes rule to improve employment of protected veterans WASHINGTON — The U.S. Department of Labor’s Office of Federal Contract Compliance Programs today announced a proposed rule to strengthen affirmative action requirements of federal contractors and subcontractors for veterans protected under the Vietnam Era Veterans’ Readjustment Assistance Act of 1974. Veterans protected by VEVRAA include those wit...
 
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