January Webinars Alert!

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Tuesday, January 14th, 2020    9:00 AM – 10:30 AM PST Tuesday Topic: OFCCP’s NEW Focused Review Guide for Section 503 (Disability AAP) Audits and Audit Evaluation Criteria OFCCP Recently published two important documents addressing focused audits for disability compliance and how the agency determines compliance.     Wednesday, January 15th, 2020    9:00 AM – 10:30 AM PT Specialized Program: The Challenges Created by Temps to Hire OFCCP audits typically focus on new hires that begin as employees of temporary help agencies.     For client access to our webinars, please contact us. We hope all clients will have at least one attendee join our webinars. Client attorneys are always...

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UPDATE: EEO-1, Component 2 Report

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Today the EEOC filled a notice in the Federal Register that it will not renew the requirement that employers submit an EEO-1, Component 2 report, at least in 2020.   Commentary This does not change the current report filing deadline of September 30th,2019. However, EEOC plans to review the outcome of the EEO-1, Component 2 before taking further action.   What This Means: All employers of 50 or more must still meet the September 30th, 2019 deadline for submitting their EEO-1, Component 2 reports for 2017 and 2018. There will not be a 2020 version of Component 2.   *** The EEO-1 Component 2 requirements apply only to employers with 100 or more employees. Here is the Federal Register Link:   As always, we welcome your...

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OFCCP CSALs and Audits are Climbing in Numbers

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Are you ready? The OFCCP broadcasted in the end of 2018 that there were going to be “more desk audits in 2019.” The time has come to be prepared for what could be a challenging time for many Federal Contractors and Federal Subcontractors both as CSAL notices continue to be sent from D.C. HR Specialties is hosting a “Tuesday Topics” webinar to talk about the specific trends of the audits and what to expect. Tuesday Topic: “OFCCPs New Approach to CSALs and Audits” Tuesday, April 16th 9:00 AM – 10:00 AM PT Also, there are compliance directives that are into effect and some soon going into effect. We will dive deep into the details and answer many questions for the “Specialized Program.” Specialized Program: OFCCPs Important 2018 & 2019 Compliance Directives Wednesday, April 17th 9:00 AM – 10:30 AM PT These webinars are at no charge for our current clients. There is a fee for non-clients. Please email for registration...

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Directive 2018 – 07

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OFCCP has recently published several new Directives with important information for employers who are federal contractors and subcontractors. One of these, Directive 2018-07, is focused on employers who are either late with yearly AAP update(s), or who fail to prepare them at all. According to this directive, OFCCP will no longer grant extensions for data submission to employers who receive audit notices. This will have significant impact on employers whose AAPs are not complete when a Compliance Review notice arrives. According to the directive, OFCCP also is considering requiring an annual renewal certification. Now is a good time to resolve to prepare 2019 AAPs on schedule. HR Specialties strongly advocates timely AAP update. Late plans can have consequences, such as failing to identify adverse impact early enough to address the cause. The complete Directive 2018-07 can be found here:

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Important Information Regarding VETS-4212

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The portal to file annual VETS-4212 reports is now open.  The filing period started on August 1st, 2018 and ends on September 30th, 2018.  Companies with federal contracts of $150,000 or more are required to file the VETS-4212 report.   Contractors will need to choose a pay period ending date that is between July 1st and August 31st.  This date will be used to create a workforce snapshot and an end period for the compilation of your companies hiring information for Veterans.  Keep in mind that contractors have the option of using a December 31st, 2017 snapshot (and January 1 – December 31st, 2017 hires data) to align with the data used for the 2018 EEO-1 report filing.   Please contact us at if you have any questions.  Questions can also be directed to VETS-4212 customer support at (866) 237-0275 or via email at...

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Town Hall Action Plan

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Last September, the OFCCP conducted a number of Town Hall Meetings where participants provided feedback and insight on compliance assistance and contractor engagement related issues.  The agency identified three focus areas around training, communication, and trust.  From these focus areas, the OFCCP developed three initiatives:   Review and enhance contractor compliance assistance materials. Assess and improve the quality of contractor and compliance officer training and education. Increase transparency and communication with agency stakeholders.   To address these initiatives, the agency created specific actions and deliverables including the replacement of outdated technical assistance guides with new guides for supply & service contractors, construction contractors, and academic institutions.  They also plan to standardize the procedures for the development of training courses or updating agency guidance. In order to increase transparency and communication, the agency has instituted the use of Predetermination Notices (PDN) in compliance reviews.  A PDN will be issued when the agency believes discrimination findings may exist and according to the OFCCP, the use of the PDN “encourages communication with contractors and provides them an opportunity to respond to preliminary findings prior to OFCCP deciding to issue a “Notice of Violation (NOV).”  The agency also plans to develop standards contractors can expect when engaging with the OFCCP.  Finally, the OFCCP will leverage technologies to open communication between contractors and the agency.   We will keep you updated as these plans start to...

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New VEVRAA Regulations from Department of Labor

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The Department of Labor & OFCCP updated the annual national hiring benchmark for protected veterans to 6.4 percent from 6.7 percent.  VEVRAA regulations require federal contractors to establish a hiring benchmark for protected veterans in order to assess the effectiveness of their outreach and recruitment efforts.  The regulations allows contractors to either calculate a benchmark using OFCCP’s guidelines or adopt the national benchmark provided by the agency.   The Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) Benchmark Database can be found here: ...

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New Round of OFCCP Scheduling Letters Sent

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The U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has sent a new round of pre-audit letters to 1,000 individual locations and facilities of federal contractors and subcontractors. This letter puts contractors on notice that their locations can anticipate an Audit Letter in the future. These were all sent to the facility directly, rather than to any corporate headquarters.   Please note that this first letter is NOT the actual Audit Scheduling Letter. It does not require any response by your organization.   We recommend checking your mailbox (and your company’s mail room) to see if your location has received a letter from the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP).  Most likely it will be addressed to “Human Resources Director”.   If you receive this letter, here’s what we recommend…   If your location is part of a multi-location employer, notify the person in charge of AAP compliance at the corporate level. These letters appear to be in place of notifying a corporate representative about all the locations where audits are planned.   If you are the corporate contact for multiple locations, we recommend alerting each facility’s local HR representative to be on the lookout for such a letter.   Please contact us at Human Resource Specialties right away to ensure that your organization has a current AAP and is prepared to respond.  Audit support is included in our annual affirmative action services to your organization.   As always, we welcome your...

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Recent Change at The OFCCP

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Ondray T. Harris is the new Office of Federal Contract Compliance Programs (OFCCP) Director.  Prior to his appointment, Mr. Harris served as a senior advisor at the Department of Labor in the Employment Training Administration.  His experience includes a number of legal consultant and advisory roles.  Under President George W. Bush, he served as the Director of the Community Relations Service at the Department of Justice (DOJ).  His legal background also includes serving as the Deputy Chief of the Employment Litigation Section of the Civil Rights Division at the DOJ. Prior to that, Mr. Harris was a partner at LeClair Ryan and an Assistant Attorney General for the Commonwealth of Virginia.   Earlier we announced that Craig Leen was to be named as the new OFCCP Director.  He will instead serve as a senior advisor to the...

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Meet Your New OFCCP Director…

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Craig Leen has been appointed as the new OFCCP Director. He replaces interim Director, Tom Dowd, who has been in the role since Patricia Shiu resigned in November of 2016. Mr. Leen has a legal background serving as the City Attorney and Chief Legal Officer for the City of Coral Gables since 2011. He received his Juris Doctor from Columbia Law School in 2000 and also serves as a volunteer adjunct professor for the University of Miami School of Law. We are closely monitoring his transition into his new role and will provide any significant updates as they...

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