Filing Period Open for EEO-1 Report

As of July 1, companies have been allowed to file their EEO-1 reports for 2014.  The filing period remains open until September 30.  EEO-1 reports can be important, as a number of federal agencies, including OFCCP and EEOC, examine EEO-1 reports when they conduct investigations, and private citizens can ask for EEO-1 data as part of a Freedom of Information Act request.  OFCCP also uses EEO-1 reports as one factor in determining which companies and facilities it will target for affirmative action reviews.  Thus, you should carefully consider how employees are reported.  For example, if your company has a number of small facilities that have typically been rolled up into one location on the EEO-1 report, you should consider reporting these employees in their separate facilities.  While OFCCP has the right to review any of a federal contractor’s facilities, it is rare for the agency to conduct a full compliance review at a facility of less than 50 people.

How to Set Priorities for an OFCCP Review

This article originally appeared in the May 2013 edition of the LocalJobNetwork "OFCCP Digest." It is the first of a two-part series.

Part 1 - Understanding How OFCCP’s Focus Areas Affect Setting Priorities

This article is the first of a two-part series. In this article, we’ll provide some general information on how to set priorities in preparation for an OFCCP review. In the follow-up article, we’ll discuss a number of specific items that should be priorities for all federal contractors and subcontractors.

The letter from the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) that opens an affirmative action compliance review sends many companies into a panic. There is concern over what must be submitted and when, how to prepare for questions that may occur, and how to deal with unexpected inquiries that may be part of the review. Many of these issues can be dealt with prior to the time a review actually begins if a company gives priority to the items that may be most important during a compliance review.

What Does OFCCP Want?

This article originally appeared in the April 2013 edition of the LocalJobNetwork "OFCCP Digest." 

Much has been written about the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) in the last few years. OFCCP has a number of significant new initiatives, most notably its recent directive regarding the evaluation of compensation data that federal contractors and subcontractors will be asked to provide during compliance reviews. OFCCP has also gone through a number of changes to the manner in which it conducts compliance reviews. For example, the agency was routinely conducting on-site investigations for a while, but OFCCP is now limiting its on-site presence and is instead requesting many additional documents during the course of a compliance review.

While we know a great deal about what OFCCP is doing, a rarely asked question is this: what does OFCCP want? Phrased somewhat differently, what are OFCCP’s expectations of federal contractors and subcontractors? And, what kind of expectations does the federal government in turn have for OFCCP?