This week, OFCCP published a request to extend the Functional Affirmative Action Program (FAAP) process with no changes to the existing requirements. The FAAP is an alternative to typical establishment-based AAPs; contractors provide detailed information to the agency and can receive approval to create functional, rather than geographic, plans. The current Office of Management and Budget (OMB) approval for the FAAP documents expires on April 30, and OFCCP has applied to extend the authorization for another three years.
Continuing its focus of ensuring the agency is covering all types of government contractors’ compliance with their affirmative action obligations, OFCCP has proposed to conduct compliance checks for construction contractors with direct federal contracts and federally assisted contracts. Comments on the proposal are due June 7, 2019.
The Office of Federal Contract Compliance Programs (“OFCCP”) held two town hall sessions in New York City this week, focused on the financial and legal industries. The town halls followed the format of earlier sessions, with attendees being asked to provide feedback about several topics, including the agency’s current enforcement practices and ideas for how the OFCCP could help contractors promote diversity in hiring, fairness in promotions and disability inclusion.
OFCCP is now accepting applications for the 2019 HIRE Vets Medallion Award! This award recognizes federal contractors who have made it their mission to hire, recruit, and retain America’s heroes. Organizations of all sizes can apply, over 230 organizations received the award last year and the process is easy and secure.
The application period is open from now through April 30. Click here for more details.
As we continue to review OFCCP’s recently-released scheduling list and the methodology the agency used to develop the list, it appears the OFCCP will first be scheduling the 500 Compliance Checks, 83 Corporate Management Compliance Evaluations (CMCE), and 72 Functional Affirmative Action Plan (FAAP) Reviews. In the middle of the last paragraph of the OFCCP’s Methodology for Developing the Supply and Service Scheduling List FY 2019, Release-1, available at: https://www.dol.gov/ofccp/scheduling/index.html it states:
Join us on April 24, 2019, from 1 to 2 p.m. EST to learn more about common employer practices that might come under scrutiny this year. In this session, Lynn Clements, a former OFCCP and EEOC official who now serves as the Director of Regulatory Affairs at Berkshire Associates, will review what the government thinks of employer policies related to use of leaves of absence as an accommodation, attendance practices, and pregnancy-related restrictions. Register today!
Do you own Berkshire’s affirmative action software, balanceAAP? Join two of Berkshire’s affirmative action experts, Sonia Chapin and Sybil Randolph of Berkshire Associates on April 10 at1 p.m. for this Section 503 webinar: Using balanceAAP to Prepare for a Section 503 Audit.
Register today and hear presenters review the elements of the Focused Review Scheduling Letter with an emphasis on responding to the letter using balanceAAP. The presenters will review technical tips for generating compliant reports as well as the reports that correspond to each item in the new scheduling letter. Finally, to ensure your organization is completely ready to respond to the new scheduling letter, Sybil and Sonia will review the information required by the scheduling letter that is not typically included in an annual affirmative action plan.
This week’s highlighted Section 503 webinar is Effectively Evaluating Outreach Towards Individuals with a Disability with affirmative action compliance expert Sonia Chapin of Berkshire Associates on April 3 at1 p.m.
As part of the Individuals with Disabilities Affirmative Action Plan, contractors are required to conduct outreach towards Individuals with Disabilities and evaluate the effectiveness of these outreach efforts. Join Sonia for a discussion of what this requirement means in practice and how it is already being applied in OFCCP audits as the agency increases its focus on contractor’s outreach efforts towards Individuals with Disabilities. Attendees will learn how to best respond to questions about outreach programs during an agency audit.