With Office of Federal Contract Compliance Programs’ (OFCCP) latest fiscal year closing on September 30, the agency and federal contractors are looking forward to 2015. This article summarizes some of the most important enforcement trends and policy developments federal contractors can expect to see from OFCCP in 2015. Buckle your seat belts—it’s going to be a busy year!
What to Expect During Compliance Reviews
If there was an OFCCP enforcement buzz word for 2014, that word might be “steering.” Steering is a placement practice, whereby intentionally or otherwise, particular genders or minorities are placed, or “steered,” into certain jobs or career paths, leading to lower overall pay and opportunity. OFCCP considers steering as a compensation discrimination issue, but most practitioners consider it a placement issue. Regardless of how you characterize it, I expect the agency’s focus on this issue will continue in 2015.
Contractors need to think a