The National Industry Liaison Group (NILG) routinely submits comments to proposed rules that affect the EEO and affirmative action obligations of federal contractors. The NILG Board believes that representing the views of our ILG constituents around the country in this manner is vital to achieving our mission and vision. Below is our comment to the OFCCP's Notice of Proposed Rulemaking on the Requirement to Report Summ...

As you have undoubtedly heard, the Office of Federal Contract Compliance Programs (OFCCP) released the revised versions of its Scheduling Letter and Itemized Listing on October 1, 2014. These documents advise federal “supply and service” contractors that the OFCCP has initiated a compliance review and set out the information required to be submitted to the agency. These new documents were effective immediately, and an...

A hypothetical conversation with a frustrated and overwhelmed federal contractor Dear Cara: I work in human resources for a federal contractor, and I keep reading about President Obama’s executive actions directed towards federal contractors. We have a very small legal department in our company, and we are having a difficult time keeping track of all these new requirements. Can you please help us?!? Dazed...

When thinking about the new developments in the OFCCP’s jurisdictional dispute with TRICARE network providers, the old adage about March weather came to mind. (The crazy spring weather we are experiencing probably also had something to do with prompting the analogy). In case you are not familiar with this ongoing saga, let me provide some history. OFCCP sues Florida HospitalThe OFCCP filed an administrative complaint aga...

Ever since the OFCCP issued its Final Rules implementing Section 503 of the Rehabilitation Act and the Vietnam Era Veterans’ Readjustment Assistance Act in September 2013, federal contractors have been concerned that the OFCCP will use the newly required collection of disability and protected veteran status from applicants as a tool to allege disparate impact on the basis of such protected status. This article will address...

The Office of Federal Contract Compliance Programs issued its revised regulations implementing Section 503 of the Rehabilitation Act and the Vietnam Era Veterans’ Readjustment Assistance Act on September 24, 2013. Since then, contractors have had more questions than answers. What is troubling is the OFCCP’s apparent failure to think through many of the obvious issues now facing contractors, and instead of incorporating an...

As attendees at any ILG National Conference can tell you, the OFCCP routinely reiterates its expectation (sometimes rather forcefully) that federal contractors know and comply with the regulations. Well, here is a case that contractors can use to remind the OFCCP that what is good for the goose is good for the gander! An Administrative Law Judge recently handed the OFCCP an embarrassing defeat in OFCCP v. VF Jeanswe...