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Category: Compliance Reporting and Recordkeeping

CWC Supports OFCCP Proposal to Renew VEVRAA Requirements

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has filed comments supporting OFCCP’s plans to renew its recordkeeping and reporting requirements under VEVRAA. The agency wants to retain the recordkeeping, reporting, and enforcement requirements in regulations implementing Section 4212 of the Vietnam Era Veterans’ Readjustment Assistance Act. These include the contents of the written affirmative action program;...
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Category: Government Contracts

Recent DOL Decision Demonstrates Debarment Risk Isn’t Just About Intentional Violations

The Department of Labor’s Administrative Review Board has affirmed a three-year debarment of a federal contractor under the Service Contract Act despite the absence of willful misconduct and the payment of all back wages and fringe benefit amounts. The issue resulted when the contractor failed to promptly implement a contract modification incorporating a new wage determination. The ARB upheld the debarment...
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Category: Disability, Accommodations, and Leaves

OMB Greenlights New OFCCP Complaint Forms

The White House Office of Management and Budget has approved for three years OFCCP’s request to change its complaint forms for processing disability and veteran employment discrimination allegations against federal contractors. The Office of Federal Contract Compliance Programs had asked permission to formally revise its Complaint of Employment Discrimination Involving a Federal Contractor or Subcontractor (Form CC-4) and Pre-Complaint Inquiry...
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Category: Government Contracts

DOL Announces 2026 Minimum Wage Rate For Contracts Still Covered By E.O. 13658

The Labor Department has announced that the federal contractor minimum wage rate will increase to $13.65 per hour on May 11, with the tipped employee cash wage rising to $9.55, for contracts covered by Executive Order 13658. This update applies only to contracts awarded between January 1, 2015, and January 29, 2022, that were not renewed or extended on or after...
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Category: Affirmative Action and DEI

Fourth Circuit Rejects Broad Challenge To DEI Certification Requirements

The Fourth Circuit has rejected a broad effort to block DEI certification requirements for federal contractors and grantees. The case is National Association of Diversity Officers in Higher Education v. Trump. The ruling resolved a challenge to portions of two Executive Orders by vacating a lower court’s preliminary injunction against agency efforts to halt funding for some DEI-related programs and...
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Category: Affirmative Action and DEI

CWC Files Comments With OMB Supporting Changes To OFCCP Complaint Form

CWC has filed comments with the Office of Management and Budget, supporting a recent request by OFCCP to formally revise two of the forms it uses to process employment discrimination allegations against federal contractors. The forms are the CC-4 (the Complaint of Employment Discrimination Involving a Federal Contractor or Subcontractor) and the CC-390 (Pre-Complaint Inquiry for Employment Discrimination Involving a Federal...
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Category: Agency Enforcement

OFCCP Seeks To Renew Veteran AAP Requirements

The Office of Federal Contract Compliance Programs has initiated the process for seeking a three-year extension for its recordkeeping, reporting, and enforcement requirements under Section 4212 of the Vietnam Era Veterans’ Readjustment Assistance Act. These include the contents of the written affirmative action program; annual outreach assessment; data collection and metrics; and regular communications to state agencies, union officials, and...
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Category: Affirmative Action and DEI

OFCCP Seeking Formal Approval To Revise Agency Complaint Forms

The Office of Federal Contract Compliance Programs has asked the Office of Management and Budget to let it revise its complaint and pre-complaint inquiry forms. OFCCP uses its Complaint of Employment Discrimination Involving a Federal Contractor or Subcontractor (Form CC-4) and Pre-Complaint Inquiry for Employment Discrimination Involving a Federal Contractor or Subcontractor (Form CC-390) to process employment discrimination allegations against...
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Category: Affirmative Action and DEI

Partial Spending Deal Would Cut EEOC Funding $20 Million In FY 2026

Congressional negotiators have reached a bipartisan deal to fund the EEOC at $435.4 million for fiscal year 2026. The funding level is the same as that requested by the White House but nearly $20 million (4.3%) less than last year’s budget. The House could vote on the agreement later this week, with Senate action expected soon. Notably, the deal does...
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Category: Government Contracts

Labor Department Rescinds Successor Contractor Hiring Mandate

The Labor Department has formally rescinded its rule requiring successor service contractors to offer jobs to the outgoing contractor’s workers. The Biden-era mandate has been without effect since January 2025, when President Trump issued E.O. 14148 directing DOL to make the change. This policy has a long history of reversals, with Democratic Presidents issuing nondisplacement mandates and Republican Presidents rescinding them....

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