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To address these initiatives, the agency created specific actions and deliverables including the replacement of outdated technical assistance guides with new guides for supply & service contractors, construction contractors, and academic institutions.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 materialize.