On May 5, 2020, the Office of Management and Budget (OMB) approved the Office of Federal Contract Compliance Programs’ (OFCCP) revised voluntary self-identification of disability form. Federal contractors and subcontractors have until August 4, 2020, to adopt the new form for applicants and employees. Pursuant to Section 503 of the Rehabilitation Act, federal contractors andRead More
On February 10, 2020, in National Women’s Law Center v. Office of Management and Budget, the U.S. District Court for the District of Columbia ordered the Equal Employment Opportunity Commission’s (EEOC’s) collection of gender and race pay data complete. This marks the end of a long-fought battle that has been raging since 2016 over whetherRead More
The Office of Federal Contract Compliance Programs (“OFCCP”) is seeking to codify its current procedures for analyzing statistical evidence of discrimination and communicating with contractors after finding potential violations of the laws it enforces. The proposed regulations provide greater clarity to the contractor community about OFCCP’s process both during and after audits. What do theRead More
On February 13, 2019, the U.S. Department of Labor, Office of Federal Contract Compliance Programs (“OFCCP”) issued Directive 2019-04, “Voluntary Enterprise-wide Review Program (VERP).” VERP is essentially an elective audit program and, while it may seem to have some appealing components, it is hard to imagine how the risk of participation would outweigh the rewardRead More