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  • by Carla Irwin - June 17, 2016
    This year marks the 10th anniversary of the Office of Federal Contract Compliance Programs’ (OFCCP) Internet Applicant Rule. Hiring violations still top the charts for financial settlements; so it is worth making sure your organization understands and is implementing the rule accurately and consistently. Here are the top three pieces of advice I give to my clients: first, develop basic qualifications;...
  • by Carla Irwin - January 22, 2016
    Well a lot. So much has happened that I will skip my usual lengthy yet insightful prose for short, sweet and to the point. Enjoy! Pay Transparency The Office of Federal Contract Compliance Programs (OFCCP) issued a final rule implementing Executive Order 13665 promoting pay transparency, which took effect January 11, 2016. The rule prohibits federal contractors and subcontractors from discriminating against...
  • by Carla Irwin - October 23, 2014
    Like we said last month, data is the foundation and a necessity to all things AA compliance. And I am sure most of you would agree we have a love/hate relationship with our applicant tracking system (ATS). Managing all of your candidates electronically is so much easier then doing it manually, but there is a constant struggle between ease of use by the recruiter, simple process for the candidate and getting all the informati...
  • by Carla Irwin - September 26, 2014
    Data is the foundation and a necessity to all things AA compliance. It can be something you get easily or it can become the bane of your AA existence. What is the difference between getting that data easily and it becoming a struggle? Technology. Now I don’t mean you have to have cutting edge systems with all the bells and whistles, but you must understand the capabilities of the systems you do have and create processes for...
  • by Carla Irwin - December 5, 2011
    Beginning in January 2011, OFCCP implemented its new audit strategy that moved the philosophy of compliance evaluations from management to enforcement. Director Shiu discontinued the previous compliance evaluation strategy of Active Case Management (ACM) and rang in the new year with a new directive, Active Case Enforcement (ACE). The switch to ACE is part of the OFCCP’s plan to continually increase efforts to enforce com...
  • by Carla Irwin - August 3, 2011
    In June, the OFCCP released a new directive outlining updates to the FAAP process. According to Director Patricia Shiu, “the FAAP is back and is better than before.” Below are excerpts from the OFCCP’s Functional Affirmative Action Program (FAAP) FAQs. Click here to read the full version. What is a Functional Affirmative Action Program? Each covered non-construction contractor must develop and maintain an af...
  • by Carla Irwin - May 20, 2011
    Federal contractors, open a bag of Frito-Lays in honor of their win against the OFCCP. The facts are as follows: On July 13, 2007, the OFCCP sent Frito-Lay a Scheduling Letter to its Dallas Baked Snack facility. As many of you know Item 10 of the Scheduling Letter requests “Data on your employment activity (applicants, hires, promotions and terminations) for the preceding AAP year and, if you are six months or more into yo...
  • by Carla Irwin - May 19, 2011
    For those of you with calendar year AAPs, this month begins the mad dash to just get your AAPs completed, but I urge you to pause and take stock of the non-statistical elements of your AAP. The OFCCP has sent out the Corporate Scheduling Announcement Letters (CSALs) and this year you will see audits handled alittle differently. Active case management has been discontinued which means focusing solely on systemic discriminatio...
  • by Carla Irwin - May 19, 2011
    The Department of Labor (DOL) recently released its Strategic Plan for Fiscal Years 2011-2016. The plan is about workers, accountability and doing what works. The Plan includes the five following goals: 1.Prepare workers for good jobs and ensure fair compensation 2.Ensure workplaces are safe and healthy 3.Assure fair and high quality worklife environments 4.Secure health benefits, and for those not working, provide inco...
  • by Carla Irwin - May 19, 2011
    On September 29th, OFCCP Deputy Director Les Jin testified before a subcommittee focusing on federal contractors and subcontractors compliance and OFCCP enforcement of veterans regulations. The testimony began with an outline of the OFCCP’s three priorities: 1. Strengthening enforcement, “Director Shiu has worked with our Regional Directors to institute a new protocol that requires OFCCP compliance officers to go on-...