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Laura A. MitchellBlog Posts

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Opening Day of the 2019 ILG National Conference

The 2019 ILG National Conference being held in Milwaukee, Wisconsin has officially begun. OFCCP Director Craig Leen opened the conference with an energized keynote addressed that touched on the agency’s work on behalf of individuals with disabilities and veterans, as well as OFCCP’s continued action in furtherance of the four “bedrock” principles announced at last... Continue Reading…
August 1, 2019

EEOC Update on Component 2 Filing

As required, EEOC has filed its scheduled update with the Court regarding the progress of collection of the new EEO-1 Component 2 pay data report. The report is brief, but notes EEOC is still on schedule to allow a data file upload function and validation process as an additional method of reporting no later than... Continue Reading…
July 29, 2019

OFCCP Issues New Guidance on Validation, Practical Significance, and Project-Based Workers

The official rules and authority that govern OFCCP’s actions are set forth in the federal regulations at 41 CFR 60.  These regulations go through notice and comment, as well as substantive review to ensure the appropriate balance of OFCCP’s jurisdiction and tools against the burden they pose on the contactor community.  Due to the formal... Continue Reading…
July 29, 2019

OFCCP Rolls Out Changes to its Functional Affirmative Action Plan Program

Functional affirmative action plans (FAAPs) are not new.  While the regulations require AAPs be prepared on an establishment-basis, OFCCP has permitted contractors to structure their AAPs by “function” or “business unit” – with Agency approval. Implicitly, the Agency’s 2013 Directive on the subject recognized that business structures had evolved since the 1960s.  Establishment-centered chains of... Continue Reading…
July 26, 2019

Mergers and Acquisitions and Other Guidance Published for Component 2 Pay Data Reporting

In an effort to provide additional guidance to employers navigating the new Component 2 pay data filing requirements, the Equal Employment Opportunity Commission (EEOC) and NORC have just updated its frequently asked questions (FAQs) with respect to how employers experiencing mergers, acquisitions, and spinoffs during 2017 and 2018 should be filing their 2017 and 2018... Continue Reading…
July 25, 2019

OFCCP Issues Pay Analysis Grouping Opinion Letter

In just its second Opinion Letter, OFCCP has [somewhat] tackled the issue of Pay Analysis Groups (PAGs).  Issued two months after the inaugural Opinion Letter which addressed the issue of Pell Grants, Director Craig Leen’s second letter touches upon the more controversial topic of compensation. In the July 22, 2019 letter, Director Leen answers the question of... Continue Reading…
July 22, 2019

Updated Proposed Focused Review Scheduling Letters: OFCCP Still Seeks Substantive Revisions

This is the third of our series of blog posts on the Office of Management and Budget’s (OMB) July 1 request for comments on OFCCP’s updated proposed scheduling letters.  For background, OFCCP first proposed changes to its existing compliance check, establishment review, and focused review scheduling letters in April, and received comments from the contractor community.... Continue Reading…
July 19, 2019

EEO-1 Pay Data Reporting Portal Open for Manual Reporting, User Guide Now Available

On schedule, EEOC has opened the portal for filing 2017 and 2018 EEO-1 Component 2 reports. Here’s the catch, however:  According to updates on the Component 2 website, the reporting portal is “operational and available for viewing by the public,” however, as it previously advised, batch reporting will not be available until mid-August. In addition, filers will... Continue Reading…
July 15, 2019

Data System Security Info and File Specifications Added to EEO-1 Pay Data Reporting Website

As July 15th draws closer, EEOC and NORC are ramping up for opening of the EEO-1 Component 2 Pay Data reporting portal. As part of these efforts, they are consistently providing new information on the reporting obligation. Please find the rest of this article on our Affirmative Action & OFCCP Law Advisor blog here.… Continue Reading
July 12, 2019

Data System Security Info and File Specifications Added to EEO-1 Pay Data Reporting Website

As July 15th draws closer, EEOC and NORC are ramping up for opening of the EEO-1 Component 2 Pay Data reporting portal. As part of these efforts, they are consistently providing new information on the reporting obligation.  Most recently, the reporting website has been updated to include assurances from NORC on data system security in... Continue Reading…
July 11, 2019

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