Morgan Consulting Services offers
more than 26 years experience with the Office of Federal Contract Compliance
Programs (OFCCP). This valuable expertise, in effective implementation
of the regulatory requirements of the Executive Order and
laws enforced by OFCCP, affords Federal contractors practical
and exclusive insight into the policies, procedures, and conciliation
measures administered by this Agency. Morgan
Consulting Services is well positioned to provide advice
on remaining current with and understanding new changes in
OFCCP and how they affect your employment practices, both
locally and corporate wide. To find out
more information about Morgan Consulting
Services, visit the About Us page or send a request using the Information Request page of this website.
OFCCP has made significant changes to their regulatory agenda for the last 3 years. The changes include:
a: utilization goals for persons with disabilities, and
b: hiring benchmarks for covered veterans.
These updates are legendary and have required significant changes to the personnel processes of Federal contractors and in the way compliance with these mandates is now measured. The regulations became effective March 24, 2014.
OFCCP is also focusing on pay discrimination, especially with regard to women. While they abandoned their compensation tool, EEOC has picked up the ball and has proposed expanding the EEO-1 report to collect pay on an annual basis.
OFCCP is continuing their aggressive regulatory agenda with the release of the Final Rule for Sex Discrimination regulations (not Guidelines). Executve Order 13672 prohibiting discrimination based on sexual orientation and gender identity became effective .
And, "straight from the horse's mouth" (as the old saying goes) a company's compliance will no longer be measured by "good faith efforts". This is a major statement and has significant implications in the world of OFCCP compliance. Any reference to "good faith efforts" now brings a discussion about using the term "effective outreach".
If you want to know more about these regulatory changes and how they impact your business, send me an email from my Information Request page and I will contact you directly.
REMINDER: While OFCCP continued the practice of sending out advance notices of expected audits, known throughout the industry as the Corporate Scheduling Announcement Letter (CSAL), these letters instead are sent directly to all locations/establishments selected/targeted for possible audit. If you get a CSAL, you can plan on an audit. In this last year of the Obama administration, few CSAL have been sent out and few new audits have been scheduled. Find out more about what this means to you or to request assistance in discovering if you are on the CSAL list by visiting my Information Request page of this website.
EEOC also has made significant regulatory and investigative changes. New Fontier in War Against Human Labor Trafficking, an interagency effort to combat trafficking and seeking justice for the victims; Title VII of the Civil Rights Act of 1964 and the ADA for enforcement of discrimination based on sex-based stereotypes such as (1) domestic or dating violence, and (2) sexual assault or stalking. Find out how social media can also play a role in employment decisions - what the employer could have known or knew from social media and whether these facts were used in employment decisions. IT CONTINUES TO BE AN AGGRESSIVE ENFORCEMENT YEAR!