September 30, 2024
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Category: Compliance Reporting and Recordkeeping

Template for Assessing Disability and Veteran Outreach

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has updated its template for assessing outreach to persons with disabilities and protected veterans. It can assist CWC’s federal contractor members in organizing their data so they’re ready if the Office of Federal Contract Compliance Programs (OFCCP) audits them. The template also should make it easier to respond to items...
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September 17, 2024
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Category: Compliance Reporting and Recordkeeping

CWC’s Updated Personnel Processes Template for Protected Vets and People with Disabilities

CWC has updated our Personnel Processes Review Template to help our federal contractor members comply with government contracting regulations related to recruitment and hiring procedures for protected veterans and individuals with disabilities. Office of Federal Contract Compliance Programs (OFCCP) regulations about protected veterans under the Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) are codified at 41 CFR Part 60-300. The...
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September 12, 2024
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Category: Executive Order

Biden’s New “Good Jobs” E.O.: Another Version of Union-Friendly “High Road”

President Biden has issued Executive Order 14126, which will require designated federal agencies to consider an employer’s labor and employment practices when awarding federal financial assistance under several recent laws. The E.O. applies to the selection of projects by “implementing agencies” for entities receiving “federal financial assistance” from the “Investing in America agenda.” By limiting coverage to grants, loans, and...
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September 10, 2024
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Category: Agency Enforcement

OFCCP Agrees to First Nationwide ERCA Since Beginning of Biden Administration

The Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) has signed an Early Resolution Conciliation Agreement (ERCA) with State Street Corporation that includes an audit moratorium on the contractor’s establishments nationwide. Although ERCAs granting a multi-year moratorium on establishment audits were common during the previous administration, this is the first ERCA of which we are aware during the Biden...
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September 09, 2024
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Category: Government Contracts

CWC’s Updated Primer on the Federal Drug-Free Workplace Act

In light of data showing increasing drug use among full-time employees in recent years, CWC thought it would be prudent to remind our members that the 1988 Drug-Free Workplace Act (DFWA) obligates covered federal contractors to provide a drug-free workplace. Therefore, we updated our DFWA primer to explain the DFWA’s coverage, contractors’ obligations, and penalties for noncompliance. The DFWA applies...
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September 05, 2024
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Category: Compliance Reporting and Recordkeeping

Responding to Item 21 on the OFCCP Scheduling Letter’s Itemized Listing

In the year since the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) began using a more burdensome Scheduling Letter and Itemized Listing to notify federal contractors of an upcoming compliance evaluation, Item 21 on the Itemized Listing has generated confusion. Item 21 asks the contractor to identify and document “policies, practices, or systems used to recruit, screen, and...
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August 27, 2024
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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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August 15, 2024
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Category: Compliance Reporting and Recordkeeping

CWC Comments to OMB Argue Against Reinstatement of OFCCP’s Burdensome Form CC-257

CWC has submitted written comments to the White House Office of Management and Budget (OMB) contending that the Office of Federal Contract Compliance Programs’ (OFCCP) request to reinstate the Monthly Employment Utilization Report (Form CC-257) is unnecessary and burdensome. The form would require covered construction contractors and subcontractors to collect and report headcount and hours-worked data by race, ethnicity, sex,...
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August 08, 2024
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Category: Compliance Reporting and Recordkeeping

2024 VETS-4212 Filing Season Underway, Submission Deadline Is September 30

The Labor Department’s Veterans’ Employment and Training Service (DOL-VETS) has opened the filing system for the VETS-4212 Report. The submission deadline is September 30, 2024. The VETS-4212 form provides a workforce snapshot by protected veteran status, as well as the number of protected veteran new hires for the preceding 12-month period. Federal contractors and subcontractors are required to file it...
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August 06, 2024
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Category: Compliance Tools

CWC’s Updated Template for Mandatory ESDS Notifications Under VEVRAA

CWC has updated a template that can assist its federal contractor members in meeting their employment service delivery system (ESDS) notice requirements. CWC’s members can use the updated template to satisfy the Office of Federal Contract Compliance Programs’ (OFCCP) ESDS notice obligations under the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) requirements codified at 41 CFR § 60-300.5(a)(4). That rule...
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