Since the Government Accountability Office (GAO) issued its Recommendations to Strengthen the Office of Federal Contract Compliance Programs’ Oversight of Federal Contractors’ Nondiscrimination Compliance in July 2016, OFCCP has taken steps to implement its recommendations. And now, the GAO has issued a progress report evaluating OFCCP’s actions toward the 2016 recommendations. The GAO’s progress report... Continue Reading…
With the future of the EEOC’s pay data collection efforts unclear, California’s effort to legislate its own race- and sex-based pay data reporting requirements likewise has stalled, for now. Since July, California’s Senate Bill 171 (requiring private employers with at least 100 employees to submit an annual report of employee pay data broken down by...… Continue Reading
The post Like EEO-1 Component 2, California Pay Data Reporting Stalls appeared first on California Workplace Law Blog.
With the future of the EEOC’s pay data collection efforts unclear, California’s effort to legislate its own race- and sex-based pay data reporting requirements likewise has stalled, for now. Since July, California’s Senate Bill 171 (requiring private employers with at least 100 employees to submit an annual report of employee pay data broken down by...… Continue Reading
Avid readers have seen that OFCCP has been busy this summer. In August alone, the Agency attended the 2019 ILG National Conference in Milwaukee, issued FAQs on student workers, proposed a new rule regarding religious exemptions, introduced a new Ombudsperson, opened a contractor assistance portal and issued multiple technical assistance guides. But, OFCCP is not content merely... Continue Reading…
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…
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…
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…
This is the second blog post in our series discussing the Office of Management and Budget’s (OMB’s) request for further comments on OFCCP’s proposed scheduling letters and itemized listings, which were first published in April. In our April post on the proposed changes to the then newly proposed establishment review scheduling letter and itemized listing,...… Continue Reading
In April, OFCCP proposed four new scheduling letters – one each for its establishment reviews, compliance checks, and separate but related letters for its focused reviews on Section 503 (disability) and VEVRAA (veteran) compliance. These proposed letters, if approved, would have significantly increased the burden of the submission required in the event of a review....… Continue Reading
The recent focus on the EEOC’s new Component 2 to its EEO-1 Report has been undeniable. It requires employers report on the race, ethnicity, sex, job type, pay, and hours worked data of its employees. OMB approved this data collection during the Obama Administration. Then, under President Donald Trump, the OMB reversed course, staying the...… Continue Reading
The post California Pay Data Reporting Advances: EEOC May Not Be Alone for Long appeared first on California Workplace Law Blog.
