March 04, 2025
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Category: Affirmative Action and Diversity

OFCCP Terminates All FAAP Agreements

The Office of Federal Contract Compliance Programs terminated all Functional Affirmative Action Program (FAAP) agreements between OFCCP and federal contractors on February 20. The agreements permitted contractors to structure their affirmative action programs (AAPs) by function rather than location. The regulations implementing Executive Order 11246 had required federal contractors to structure their AAPs by location unless OFCCP approved a different...
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February 26, 2025
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Category: Government Contracts

CWC’s Updated Subcontractor and Vendor Notification Template

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has updated its subcontractor and vendor notification template to assist federal contractors in complying with Section 503 and VEVRAA. This communication is mandated by OFCCP regulations implementing Section 503 of the Rehabilitation Act and Section 4212 of the Vietnam Era Veterans’ Readjustment Assistance Act. CWC members may use the...
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February 05, 2025
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Category: Discrimination and Harassment

CWC Holds Member Roundtable To Discuss Rescission of E.O. 11246

CWC held a members-only roundtable January 29 to discuss Executive Order 14173, which rescinded long-standing Executive Order 11246. President Trump issued E.O. 14173, titled “Ending Illegal Discrimination and Restoring Merit-Based Opportunity,” on January 21. It rescinds E.O. 11246 and requires federal contractors to certify that they are not operating any programs promoting diversity, equity, and inclusion that violate federal anti-discrimination laws. During...
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February 04, 2025
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Category: Agency Enforcement

Michael Schloss Appointed as OFCCP’s Deputy Director of Policy and Acting Director

The Trump Administration has appointed Michael Schloss as the Deputy Director of Policy and Acting Director at the Office of Federal Contract Compliance Programs (OFCCP). Mr. Schloss is an ERISA attorney who previously served as a career official at the Labor Department’s Employee Benefits Security Administration (EBSA). He retired in January 2023 as EBSA’s Director of Enforcement. He rejoined EBSA...
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January 27, 2025
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Category: Affirmative Action and Diversity

Acting Secretary of Labor Micone Orders OFCCP To Halt All E.O. 11246 Investigations

Acting Labor Secretary Vincent Micone has ordered DOL personnel to cease all enforcement activities under rescinded Executive Order 11246 and to pause enforcement activities under VEVRAA and Section 503 of the Rehabilitation Act of 1973 pending further guidance. Secretary’s Order 03-2025, issued January 24, 2025, covers “all pending cases, conciliation agreements, investigations, complaints, and any other enforcement-related or investigative activity.”...
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January 23, 2025
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Category: Affirmative Action and Diversity

President Trump Rescinds E.O. 11246

President Trump has issued a new Executive Order formally rescinding Executive Order 11246 and directing the Office of Federal Contract Compliance Programs (OFCCP) to cease holding federal contractors responsible for taking affirmative action. Executive Order 11246 was signed by President Johnson in 1965, and prohibits covered federal contractors from discriminating in employment on the basis of race and sex, among...
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January 09, 2025
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Category: Agency Enforcement

EEOC and OFCCP Modify Long-Standing MOU; DOJ Ends Its Participation

The Equal Employment Opportunity Commission and DOL’s Office of Federal Contract Compliance Programs signed a new Memorandum of Understanding (MOU) December 17, 2024, outlining how they will share information and process discrimination charges and complaints. Before doing so, the agencies rescinded a similar 2020 MOU that included the Department of Justice. The EEOC enforces Title VII of the 1964 Civil...
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December 19, 2024
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Category: Agency Enforcement

OFCCP Audits, Financial Remedies Decreased in FY 2024

OFCCP had a slow year in FY 2024, awarding less money in discrimination cases to fewer class members and completing fewer audits than at any time in recent memory, according to enforcement data released by the agency. The data, which cover the period from October 1, 2023, to September 30, 2024, show that OFCCP completed 14% fewer supply-and-service (non-construction) audits...
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December 09, 2024
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Category: Discrimination and Harassment

OFCCP Publishes Guide on Combatting Harassment in the Construction Industry

The Labor Department’s Office of Federal Contract Compliance Programs has published A Guide to Combatting Harassment in the Construction Industry. The guide, released in November, uses a question-and-answer format. Though the guide focuses on federal construction contractors, other employers can use it to better understand and prevent harassment in the workplace. The guide explains that construction contractors have an affirmative obligation...
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December 03, 2024
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Category: Compliance Reporting and Recordkeeping

OFCCP Construction Contractor Utilization Report Due April 2025 (and Every Month Thereafter)

Federal construction contractors and subcontractors must begin filing their monthly CC-257 forms April 15, 2025, the Labor Department’s Office of Federal Contract Compliance Programs announced. Employers that have a federal construction contract or subcontract, or a contract in which federal funds pay for construction work worth more than $10,000, must submit a Monthly Employment Utilization Report (CC-257) to OFCCP on...
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