New OFCCP Federal Contract Compliance Manual Has Many Provocative Surprises:
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