Part I reviewed the OFCCP’s many accomplishments in 2013 and discussed their implications for 2014. Its 2014 agenda appears no less ambitious (more on that soon). Let’s briefly compare the OFCCP of the Clinton, Bush and Obama years to get an idea of what likely lies ahead.

The Clinton Years: Director Shirley Wilcher took a strong interest in compensation issues and, initially, a tough stance on employment discrimination in general. Yet the OFCCP’s focus on technical compliance (e.g. posting, outreach) did not appear to change too much. Her proposed EEO Survey intended to cause contractors to start counting and reporting compensation, was one exception. Her successor, however, ultimately withdrew that proposal. The OFCCP under Clinton/Wilcher appears to focus more on the depth and length of compliance reviews rather than the number of