October 2013

What It All Means: Where Is OFCCP Taking You: Carter to Clinton to Obama

Punch line: It’s all about documentation, just when you have fired and transferred all of your document clerks.

Weldon Rougeau, the Carter Administration OFCCP Director, forever changed OFCCP and laid the foundation bricks for the building Pat Shiu and the Obama Administration are now constructing on Director Rougeau’s foundation.

Before Director Rougeau, OFCCP was a federal contractor agency requiring Affirmative Action. While Executive Order 11246 (but not Section 503 or VEVRAA) had non-discrimination authority to be sure, the agency rarely pursued discrimination investigations. Moreover, it lacked regulations allowing it to file Administrative Complaints before Administrative Law Judges seeking back pay. This was not an early oversight – the Congress had specifically declined to grant OFCCP such authority, or t