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I Think My Company is a Federal Contractor and Has Regulatory Obligations - But Where Can I Look to Search for That Information?
Topic: AAP |
| Doing business with the United States federal government can be very lucrative, but it comes with a price. That price arrives in the form of reporting obligations, recordkeeping, outreach, and much more! Failure to comply with all applicable regulatory requirements can also have...more |
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Christopher J. Near
Of Counsel, Ogletree, Deakins, Nash, Smoak & Stewart, P.C. |
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Kiosha H. Dickey
Of Counsel, Ogletree, Deakins, Nash, Smoak & Stewart, P.C. |
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Ask the Experts is an online forum where federal contractors and subcontractors are invited to submit questions to industry experts related to OFCCP compliance, affirmative action planning, and equal employment opportunity. Simply register your company on LocalJobNetwork.com to submit a question. Questions and answers will occasionally be featured in The OFCCP Digest for the benefit of all readers.
Question: Tracking Applicant Accommodations
| Are federal contractors required to track/document reasonable accommodations made for applicants in order to comply with a potential OFCCP audit? If so, what is the best way to do this? |
Answered by Carla Irwin from Carla Irwin & Associates, Inc.:
Number 20 of the Itemized Listing does include documentation of all requested accommodations and their resolution. That would include any accommodations requested by applicants. Here is a link to the itemized listing.
With regard to the best way to track and document the information, that is really dependent upon your recruiting process. In general, I would suggest identifying who is responsible for taking the requests at each stage of the recruiting/hiring process and creating a template/form for them to complete. Identify a centralized depository and review the documentation on a regular basis. |
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Executive Order Plans to Reorganize the Executive Branch and Federal Agencies
President Donald Trump issued a new Executive Order to reorganize the executive branch in an effort to improve accountability and efficiency. The order directs the Office of Management and Budget (OMB) to come up with a plan to reorganize governmental functions and eliminate unnecessary agencies. The plan shall include an invitation to the public to suggest improvements for the OMB to consider.
Senate Votes to Rescind the Fair Pay and Safe Workplaces Regulation
In a close vote, the U.S. Senate approved to repeal Executive Order 13673: Fair Pay and Safe Workplaces. The order, best known as the “Blacklisting” Rule, would require all federal contractors to publicly report labor violations. Last October, a Texas judge temporarily stopped the implementation of EO 13673, but the “paycheck transparency” provisions of the regulation still went into effect on January 1, 2017. Now the matter goes to President Trump, who is expected to sign the bill to formally stop the order. This would make Executive Order 13673 invalid and prevent its regulations and requirements from being implemented.
Non-Substantive Change to OFCCP Pay Transparency Provision
OFCCP recently added the Regulatory Citation (41 CFR 60-1.35c) to the Pay Transparency Nondiscrimination Provision. Each employer covered by Executive Order 11246 must post this provision and incorporate it in their employee handbooks or manuals. While this change to the provision is non-substantive, the National Industry Liaison Group (NILG) and OFCCP acknowledged that contractors should take action to apply the revised provision as soon as their business practices would allow.
OFCCP Distributes Corporate Scheduling Announcement Letters to 800 Establishments
On February 17th, OFCCP sent out 800 Corporate Scheduling Announcement Letters (CSAL) to 375 “distinct companies” across 29 industries. The CSAL gives these establishments advance notice of upcoming audits based on the list generated by the Federal Contractor Selection System (FCSS). The DOL website has an FAQ on items related to this particular round of CSALs. This was categorized as the “first release” of CSALs in 2017; however, there was no indication if or when another round of CSALs will be distributed. This is the first time since July 2014 that the OFCCP has issued CSALs.
Read more DOL Highlights throughout the month for timely updates. |
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Women’s History Month, which is celebrated in March, recognizes the contributions of women in the workforce. As part of the celebration, the Department of Labor is sharing interesting facts and figures about the participation women in the US labor force. You can find more information on the DOL website. |
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Contact Us
The OFCCP Digest is a complimentary resource featuring affirmative action, equal employment opportunity, and government compliance topics. Previous editions are available for easy reference on The OFCCP Digest Archives page. To subscribe or to provide feedback, email OFCCPDigest@LocalJobNetwork.com. |
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| The opinions expressed in this newsletter are the opinions of the individual author(s) and do not necessarily reflect the opinions of the Local JobNetwork™. The information appearing in this newsletter is meant to provide the reader with a general understanding of topics relating to OFCCP compliance requirements and is not legal advice. If you are seeking legal advice to address OFCCP compliance issues or requirements, you should consult an attorney. The Local JobNetwork™ expressly disclaims all liability with respect to actions taken or not taken based on any or all of the contents of this newsletter. |
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