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Category: Comment Letter

CWC Urges USDA To Keep “Blacklisting” Out of Its Revised Procurement Regulations

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, filed comments August 27 supporting the U.S. Department of Agriculture’s decision to drop controversial blacklisting provisions from its proposed overhaul of its procurement regulations. USDA’s decision to drop the provisions is a reversal from the proposed overhaul of the Agriculture Acquisition Regulation (AGAR) that the agency published two years...
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Category: Comment Letter

CWC Comments Urge OFCCP To Amend Proposed Construction Contractor Scheduling Letter

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, wrote a comment letter to the Labor Department’s Office of Federal Contract Compliance Programs urging OFCCP to abandon expansive changes it is proposing to the Scheduling Letter through which it notifies federal construction contractors of an upcoming compliance evaluation. OFCCP solicited public comments on its proposed changes, as required...
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Category: Comment Letter

CWC Comments to OFCCP Question Need for Reinstatement of Construction Contractor Form CC-257

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has submitted comments to the Labor Department’s Office of Contract Compliance Programs (OFCCP) on its proposal to reinstate a monthly version of its long-discontinued Utilization Report (Form CC-257) for federal construction contractors and subcontractors. CWC’s comments support OFCCP’s efforts to improve the process for scheduling federal contractors for compliance...
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Category: Comment Letter

CWC Comments to EEOC on PWFA Procedural Rules Urge Greater Transparency Re: Process Used

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, filed comments with the U.S. Equal Employment Opportunity Commission endorsing EEOC’s recently revised procedural regulations as being consistent with the Pregnant Workers Fairness Act (PWFA). The comments also express CWC’s concern that EEOC did not give the public an opportunity to comment until after it finalized the rules. The revisions...
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Category: Comment Letter

CWC Comments to OMB Support DOL’s Request To Extend the VETS-4212, Without Change

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has filed comments with OMB supporting a request from the Labor Department’s Veterans’ Employment and Training Service (DOL-VETS) to extend the Federal Contractor Veterans’ Employment Report (VETS-4212) for three more years. Approval from the White House Office of Management and Budget, which is expected soon, is the final step...
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Category: Comment Letter

CWC Files Comments on Proposed Federal Contractor Pay Transparency Regulations

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has filed comments with the White House Office of Federal Procurement Policy (OFPP) and the Federal Acquisition Regulatory (FAR) Council in response to the proposed rule on Pay Equity and Transparency in Federal Contracting. The proposal would require contractors to disclose salary and benefits in advertisements for jobs to be...
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Category: Comment Letter

CWC’s Comments to OFCCP Urge Burden-Easing Changes to Contractor Portal

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has filed written comments with the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) urging it to reduce the compliance burden posed by its contractor portal. CWC’s comments responded to the agency’s announced intent to seek  approval from the White House Office of Management and Budget (OMB) to...
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Category: Comment Letter

CWC Comments to DOL Object to Proposal for Expanding White Collar Overtime Pay

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has filed written comments with the Department of Labor (DOL) objecting to its proposed rule that would substantially increase the salary test for white-collar overtime regulations. CWC’s comments question whether the proposal is needed and whether it exceeds DOL’s authority under the Fair Labor Standards Act (FLSA). If finalized...
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Category: Comment Letter

CWC Urges EEOC To Conform New Workplace Harassment Guidance to Established Legal Principles

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has filed written comments with the Equal Employment Opportunity Commission (EEOC or Commission) on its proposed enforcement guidance on workplace harassment liability. Once adopted, the revised guidance will supersede existing guidance on the topic issued by the Commission over the last two decades. Our comments support the commission’s goal...

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