As we stand back and examine what happened during 2018, it is natural to simply catalogue the numerous changes that occurred at the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP). There were multiple new directives, new initiatives, and new personnel at the agency. There were actions taken that we had never seen before from the agency, including the public release of information on how the agency chooses organizations for compliance review. Programs to recognize voluntary efforts by federal contractors and subcontractors were reintroduced, and issues that were troubling to the federal contractor community were addressed.

A common theme unifying OFCCP’s current approach to enforcing its regulatory mandates might be summed up with the label &