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Industries: Health Care and Social Assistance

Tips on Responding to New Scheduling Letter and Itemized Listing — Part II

This article is a companion to an article in the March 2015 edition of The OFCCP Digest. As we noted there, on October 1, 2014, the U.S. Department of Labor’s...

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Signs of Troubling Times Ahead for OFCCP’s Approach to Manufacturing Comparators, Comparisons, and Discrimination

Discrimination cases are essentially “games” of making relevant, suitable, or valid comparisons between suitable, valid, or appropriate comparator(s). While anti-discrimination laws do not define discrimination in a comparative sense, comparators...

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Tips on Responding to New Scheduling Letter and Itemized Listing

When the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) begins an affirmative action compliance review, it sends the organization subject to the review a letter that...

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Choosing an Affirmative Action Plan Structure

IntroductionIn a time of changing laws and a pervasive fear of OFCCP audits, it is always a good idea to make sure that people have a good understanding of the...

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A Quick Look at the OFCCP’s Enforcement Data for Fiscal Year 2010 to 2015 – Part II

In the previous part of this article (Part I), I reviewed some of the enforcement data the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has made...

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The OFCCP’s Proposed Regulations on Sex Discrimination and What They Mean for Contractors

On January 30, 2015, the Office of Federal Contract Compliance Programs (“OFCCP”) published its proposed rule regarding updates to the current guidelines governing discrimination on the basis of sex. According...

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President Obama and the OFCCP: Looking Ahead to 2015 and Beyond – Part III

In our last two posts, we examined key actions taken by the OFCCP in 2014 through the lens of President Obama’s ambitious agenda. While some OFCCP actions have reflected Mr....

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President Obama and the OFCCP: 2014 in Review – Part II

In Part I of this post we examined the close connection between the OFCCP’s focus on pay equity and the hiring of veterans and individuals with disabilities (IWDs) in 2014...

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Eight Ways to Survive an OFCCP Audit

The key to surviving a compliance review, or audit, is in preparing the AAP—way before the scheduling letter is received. Remember, a compliance review focuses on the activity from the...

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