August 2013

New OFCCP Federal Contract Compliance Manual Has Many Provocative Surprises:
Head-Knocking in Audits Lies Ahead

Because OFCCP has not yet released the new “Federal Contract Compliance Manual” (“FCCM”) to the public even while the agency uses it to train its Compliance Officers, I thought I would devote this column to the new FCCM and report (“verbatim”) some of its more provocative content. Because you do not have copies of it, I did not want to summarize it. Rather, I wanted you to see for yourself whether I had faithfully characterized what I am reading. The new FCCM is dated July 2013 and is a streamlined and svelte 486 pages long. The new 2013 FCCM replaces the 730 page 1998 OFCCP FCCM, effective already.

SUMMARY: While the new FCCM is very well written, and understandable, there are many highly provocative policy changes which affect audits in