OFCCP Encourages Development of Functional AAPs

Posted by Cindy Karrow, SPHR, SHRM-SCP, Senior HR Consultant on September 14 2018

OFCCP demonstrated they are listening to federal contractors about the way businesses operate in the current environment. For many contractors, business does not operate out of a single establishment address but from a number of work spaces, including company owned or leased establishments, shared work spaces, client locations, and home offices. Business functions are spread among multiple physical locations, and developing an AAP for each location does not provide leaders with an effective affirmative action analysis for their area of responsibility. Additionally, a single business location may house multiple functions which makes it nearly impossible to provide a meaningful analysis or assign responsibility when the functions are grouped together. 

Federal Minimum Wage is Increased for Federal Contractors

Posted by Lauren Buerger on September 14 2018

According to a final ruling announced by the Department of Labor in September 2017, the hourly minimum wage for employees performing work on or in connection with federal contracts will be raised as of January 1, 2019. For organizations covered by Executive Order 13658, the new rates will be $10.60/hour (from $10.35/hour) and $7.40/hour (from $7.25/hour) for tipped employees.

OFCCP Releases New Contractor Resource

Posted by Sonia Chapin, SPHR, SHRM-SCP on September 14 2018

Amidst a flurry of recent activity, OFCCP added a new section to their website that provides access to several resources for federal contractors and federal agency contracting officials. This is part of the agency’s ongoing efforts to provide transparency and enhance affirmative action compliance assistance available to contractors, and includes the following:

DOL Launches Compliance Focused Office

Posted by Kelly Andrews, PHR, SHRM-CP on September 7 2018

Recently, the Department of Labor (DOL) announced it is creating a new sub-office tasked with helping businesses comply with more than 100 safety, wage, and benefit laws the Department administers. The office will be labeled as the Office of Compliance Initiatives (OCI) and will work with the DOL’s enforcement-focused sub-agencies on compliance outreach activities. In addition, the agency will develop new ways to use data to strengthen compliance and help enforce the law.

More CSAL letters on the way!

Posted by Cindy Karrow, SPHR, SHRM-SCP, Senior HR Consultant on September 7 2018

Surprise! OFCCP announced today (September 7, 2018) that it just mailed out 750 additional Corporate Scheduling Announcement (CSAL) letters to contractor establishments. This list is a supplement to the previously issued list from March 19, 2018.

OFCCP Announces Contractor Award Recognition Program

Posted by Lynn A. Clements, Director, Regulatory Affairs on September 7 2018

Based on feedback received from contractors in 2017 and early 2018, the OFCCP announced plans to create a federal contractor recognition program in a new Directive issued August 24, 2018. The new Directive, Directive 2018-06, Contractor Recognition Programs, can be accessed here.

OFCCP Takes Steps to Verify All Contractors Are Preparing a Timely Annual AAP—Are You in Compliance?

Posted by Lynn A. Clements, Director, Regulatory Affairs on September 6 2018

OFCCP recently announced it will soon begin asking all federal contractors and subcontractors to verify they are preparing a written annual affirmative action plan (AAP) through an annual certification program within 30 days of receiving an official scheduling letter. This request is a part of the Affirmative Action Program Verification Initiative Directive–Directive 2018-07.

VETS-4212 and EEO-1 Reporting Update

Posted by Sonia Chapin, SPHR, SHRM-SCP on September 5 2018

While the VETS-4212 deadline is looming at the end of this month, several clients are looking forward to 2019. Many are wondering if the community should prepare for changes to the EEO-1 report. As far as we can predict, there will be no change to the report—that is, it will be based on employer data from the fourth quarter of 2018 and due on March 31, 2019. The EEOC has not signaled that the compensation section—approved in September 2016 and placed on hold in August 2017—will be included in the 2018 filing. Clients looking to consolidate EEO-1, VETS-4212, and AAP reporting requirements are advised to select a plan date of January 1 or complete update plans for their July 1 plans. The AAP and EEO-1 data can be generated by the time the EEO-1 report is due at the end of March, and the same data can be filed for the VETS-4212 reports due in September.

Hope Solo Strikes Again at the Women’s Pay Gap

Posted by Suzanne Keys, SPHR, SHRM-SCP, HR Consultant on August 31 2018

Hope Solo, a former goalkeeper for the U.S. women’s national soccer team, has filed a lawsuit in California Federal Court against the U.S. Soccer Federation for violating the Equal Pay Act.

OFCCP Religious Exemption Directive

Posted by Sonia Chapin, SPHR, SHRM-SCP on August 29 2018

Several new pieces of guidance came out during and following the NILG conference held earlier this month. A few notable directives include the Contractors “bill of rights” and the directive about focused reviews in fiscal year 2019. Berkshire clients should also note the recent directive issued addressing OFCCP’s new plans to address religious organizations under its jurisdiction.