June 03, 2022
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Category: Agency Enforcement

OFCCP Now Saying That Small AAPs Must Be Added to AAP-VI

In an unexpected and frankly disturbing new development, especially in light of its timing and earlier agency guidance, the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) announced late last week that establishments with fewer than 50 employees must be added to the agency’s online Affirmative Action Program Verification Interface (AAP-VI) Contractor Portal, if the contractor maintains an affirmative...
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June 03, 2022
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Category: Agency Enforcement

What To Expect From OFCCP’s Upcoming “Modernizing AAPs” Proposal

Sometime later this year, perhaps as early as September, the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) is expected to publish a formal proposal entitled Modernizing Affirmative Action Programs, Recordkeeping, and Other Components of the Executive Order 11246 Supply and Service Obligations for Federal Contractors and Subcontractors. The “Modernizing AAPs” proposal is the most ambitious of several new...
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May 27, 2022
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Category: Agency Enforcement

OFCCP Posts New “CSAL” List Targeting 400 Establishments for Compliance Audits

The Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) has posted online a new list – formally known as the Corporate Scheduling Announcement List (CSAL) – targeting 400 federal contractor establishments for an upcoming compliance evaluation. The new FY 2022 CSAL identifies the type of review for which each entity on the list has been flagged, broken down as...
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May 27, 2022
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Category: Agency Enforcement

OFCCP Introduces AAP-VI Bulk Upload Option for Multi-Establishment Contractors

The Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) has announced an option for federal contractors and subcontractors with 100 or more establishments (or functions) to upload or modify establishment information into the agency’s Affirmative Action Program Verification Interface (AAP-VI) Contractor Portal. As we reported previously, all supply and service contractors subject to OFCCP’s jurisdiction must certify by June...
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May 20, 2022
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Category: Agency Enforcement

OFCCP Key Personnel Update

In the sixteen months that have transpired since President Biden appointed Jenny Yang as the Director of the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP), there have been several key personnel changes, some of which we’ve previously brought to your attention. Given the major policy developments at the agency that have occurred within the last few months, we...
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May 13, 2022
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Category: Agency Enforcement

OFCCP Financial Settlement Update – May 2022

To help federal contractor keep up with recent enforcement trends out of the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP), for the last several years we have been summarizing, on a periodic basis, major settlements announced by OFCCP that involve financial remedies. And while the pace of settlements clearly accelerated during the last year of the Trump Administration,...
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April 08, 2022
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Category: Agency Enforcement

New OFCCP Directive Signals Return of Aggressive Enforcement

Office of Federal Contract Compliance Programs (OFCCP) Director Jenny Yang has issued a second major policy directive in as many weeks, in this instance formally scrapping many of the cooperative compliance evaluation policies that were implemented by former Trump OFCCP Director Craig Leen. Director Yang’s newest directive follows on the controversial new directive (DIR 2022-01) she signed on March 15...
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April 08, 2022
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Category: Agency Enforcement

OFCCP Posts New AAP-VI FAQs

No later than June 30 of this year, covered federal contractors and subcontractors must certify to the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) via an online “Affirmative Action Program Verification Interface (AAP-VI)” that they have developed and maintained Affirmative Action Programs (AAPs) in accordance with OFCCP’s regulations. And while covered federal contractors have been able to register...
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April 08, 2022
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Category: Agency Enforcement

New AG Guidelines on FOIA “Presumption of Openness” Could Impact Workforce Data Disclosure

U.S. Attorney General Merrick Garland recently issued new guidelines reminding federal agencies that the federal Freedom of Information Act (FOIA) favors transparency and the disclosure of information in the government’s possession. Although the new guidelines don’t alter FOIA’s current exemptions from disclosure, the guidelines do send a strong signal that as a matter of policy the Biden Administration encourages the...
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April 01, 2022
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Category: Agency Enforcement

Comments Filed Urging USDA To Withdraw Blacklisting Proposal

Our affiliated non-profit association, the Center for Workplace Compliance (CWC), as filed written comments with the U.S. Department of Agriculture (USDA) regarding that agency’s latest attempt to amend its procurement regulations to require USDA contractors to certify compliance with “all applicable labor laws” and deny contracts to bidders based on USDA’s assessment of their compliance records. As we reported recently,...
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