OFCCP Issues Three New Directives

Posted by Cheryl Boyer, SPHR, SHRM-SCP, Vice President of Client Services on December 3 2018

The OFCCP has issued three additional directives. Directive 2019–02 outlines the process the OFCCP will use for early resolution of identified violations. With the Early Resolution Procedures or ERP, OFCCP and contractors with multiple establishments can agree to resolve problems quickly with a variety of actions, dependent upon the identified violation.

Scary Audit Stories

Posted by Sonia Chapin, SPHR, SHRM-SCP on October 26 2018

Just in time for Halloween, OFCCP has been busy with what some may think are scary activities. Contractors with locations on the latest CSAL list are beginning to receive the initial phone calls to schedule their compliance reviews. The scheduling letters were said to start being mailed out on October 22, 2018.

The Latest Directives from the OFCCP

Posted by Michiko Clark, Associate HR Consultant on September 21 2018

The OFCCP announced two new directives on Wednesday, September 19, 2018. Acting Director Craig Leen announced the Transparency in OFCCP Compliance Activities Directive and the OFCCP Ombud Service Directive, which brings to nine the number of Directives issued thus far this year.

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. 

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.

Learn How OFCCP Examines Employment Practices During Atlanta Metro ILG Meeting in September

Posted by January Mallory on August 29 2018

Register and attend the Metro Atlanta ILG meeting where Berkshire’s Director of Regulatory Affairs, Lynn Clements will share how to prepare onsite compliance reviews on September 13 in a presentation entitled, “Under the Microscope: How the Government Examines Your Employment Practices Under the ADA and Section 503.”

OFCCP Announces New Directives

Posted by Kelly Andrews, PHR, SHRM-CP on August 24 2018

Today, OFCCP announced three different directives geared towards maximizing the success of compliance assistance outreach for federal contractors. The directives include new procedures for reviewing compensation practices, a program to verify that contractors are in full compliance with federal AAP requirements, as well as an initiative that will establish a program that recognizes contractors with high-quality and high-performing compliance initiatives.

Get Ready for Focused Reviews!!!

Posted by Cindy Karrow, SPHR, SHRM-SCP, Senior HR Consultant on August 17 2018

This week OFCCP announced they would include focused reviews in future scheduling lists as they implement a comprehensive initiative aimed at ensuring that contractors comply with anti-discrimination and equal employment opportunity regulations.

Get Ready! New Scheduling Letters Will be Mailed Beginning March 19, 2018

Posted by Lynn A. Clements, Director, Regulatory Affairs on February 15 2018

Updated on February 15, 2018:

OFCCP has updated the Frequently Asked Questions (FAQs) related to the recently-issued Corporate Scheduling Announcement Letters (CSAL) to indicate that contractor’s requests for extensions for submitting AAPs will be closely scrutinized and not routinely granted. The agency takes the position that contractors are receiving 45 days’ notice with the initial CSAL, and have an additional 30 days to submit the plan when the scheduling letter is received. Berkshire recommends that contractors take steps now to ensure locations on the advance notice list are prepared for an OFCCP audit in 2018.  The full text of the OFCCP’s FAQs is available here.

HR Consultant, Rachel Rubino, Shares Insight on OFCCP Audit Under the Trump Administration During Hampton Roads ILG Meeting

Posted by January Mallory on February 9 2018

On March 1, 2018, Rachel Rubino, MS, SPHR, SHRM-SCP of Berkshire Associates Inc., will share with Hampton Roads ILG members her unique perspective on the current administration’s impact on OFCCP enforcement efforts, and how HR professionals can prepare for what’s to come.