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. The OFCCP issued 2 more Directives in September and published notice (with supplemental documents) of a proposed 3rd, which would amend DIR 2013-01 Revision 1 (and make easier on contractors) the approval for and use of functional AAPs. DIR 2018-08 announces further steps that agency field personnel must take to promote transparency in compliance evaluations, and provides specific steps and procedures to be used in requesting, receiving, analyzing and resolving adverse findings. DIR 2018-09 announces the creation of an Ombud Service at OFCCP to assist stakeholders (contractors as well as worker representative organizations).