901 East Cary Street
This has been a significant year for employers subject to regulation by the Office of Federal Contract Compliance Programs. OFCCP regulations, directives and enforcement initiatives adopted during 2013 will hit federal contractors and subcontractors with full force in 2014. Preparation is necessary for a successful defense to the next wave of compliance reviews and investigations.
- New VEVRAA regulations, published Sept. 24, 2013, and effective March 24, 2014, including for the first time an 8 percent hiring “benchmark” for protected veterans.
- New Section 503 Rehabilitation Act regulations, published Sept. 24, 2013, and effective March 24, 2014, including for the first time a 7 percent “utilization goal” for employment of individuals with disabilities in each job group.
- Directive 307, effective Feb. 13, 2013, establishing a new approach to evaluating compensation practices.
- Directive 310, issued July 17, 2013, providing a new, and more costly, approach to determining back pay liability for alleged violations.
- Directive 306, issued on Jan. 29, 2013, detailing OFCCP’s new scrutiny of criminal background checks as discriminatory.
- The new Federal Contractor Compliance Manual (FCCM), issued on Aug. 27, 2013, revising OFCCP’s compliance review and enforcement procedures.
- More detailed desk audits pending OMB action on the new Scheduling Letter and Itemized Listing.
- Implications of the confirmation of Thomas Perez as Secretary of Labor on July 18, 2013.