Fed Insights

Federal Announcements and Updates

 

As changes are made to the employment requirements under federal contracts by actions of the administration or congress, Pillar updates its guide in a timely fashion. The changes (or possible changes being considered) for the current year are reflected below with some commentary on each.  A full discussion of each subject is contained in Pillar’s Employment Requirements of Federal Contractors and Subcontractors.

Form EEO-1 Summary Compensation Data, Part II

The D.C. District Court’s follow up Order (issued verbally from the bench April 25, 2019, written Order posted in Court’s docket folder April 26, 2019 and will be linked here once made public) to its March 4th Order vacating the OMB’s stay on the Component 2 summary compensation data collection, requires the EEOC to collect and employers to report, Component 2 data by September 30, 2019.

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Form EEO-1 Summary Compensation Data

On March 4, 2019, a D.C. Federal District Court Vacated the review and stay described below. Further commentary on the court’s Order follows at the end. On August 29, 2017 the EEOC announced that it had received a Memorandum from the OMB (OIRA), which put a hold on the previous OMB authorization for the new information collection (summary compensation data) for reporting year 2017, and left the traditional Form EEO-1 reporting requirements unchanged from previous years.

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OFCCP Incentivizes Contractors to Volunteer Establishments for Review

Expanding the DIR 2019-02 model of offering exemption from randomly selected reviews at any establishment to a contractor who voluntarily submits multiple establishments for review (DIR 2019-02 offers exemption from random selection of any establishment for the period of a consent decree which applies the remedy for a violation in one establishment to additional establishments, the contractor voluntarily submitting those additional establishments to consent decree jurisdiction).

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November Is (You Guessed It, Also) National OFCCP Directive Month

On November 29, the agency issued 3 new Directives, the first, DIR 2019-01, rescinds the previous administration’s deep dive audit protocols (while pointing out that some of that methodology has been incorporated into agency procedures), and provides a limiting instruction for onsite audits, which is that their scope be solely those issues that triggered the onsite review. 

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September Is (Also) National OFCCP Directive Month

The OFCCP continues to take decisive and robust actions in attempting to make the compliance process more amenable and respectful to contractors, and to take responsibility for assisting contractor compliance through better outreach, education and responsiveness. 

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