Affirmative Action & OFCCP Law Advisor

A source of insights, news and strategy on affirmative action and EEO compliance matters

In April, OFCCP proposed four new scheduling letters – one each for its establishment reviews, compliance checks, and separate but related letters for its focused reviews on Section 503 (disability) and VEVRAA (veteran) compliance. These proposed letters, if approved, would have significantly increased the burden of the submission required in the event of a review. The notice and comment period closed for these letters on June 11, with many weighing in with questions,…
As we previously reported, on July 2, EEOC updated the its newly created website with long-awaited materials regarding the obligation of employers with 100 or more employees to submit pay data and hours worked data as part of the annual EEO-1 reporting obligations. We anticipated EEOC would not change much relative to the materials the Agency published in 2016. For the most part that’s true but below is a summary of important changes,…
As we approach the July 15 date on which EEOC expects to open the portal to file EEO-1 Component 2 pay data reports, EEOC has at long last provided us with guidance materials:  https://eeoccomp2.norc.org/faq.html .  The most helpful materials can be found by clicking on the “More Info” Tab at the top right of the web page.  There you will find a sample reporting form, Instructions, a User’s Guide and other materials.  At first glance…
On Friday, the Office of Management and Budget (OMB) published notice it would begin reviewing the proposed changes to OFCCP’s Supply and Service scheduling letters, including the Section 503 and VEVRAA Focused Reviews and Compliance Check letters. OMB is seeking public comments until July 29, 2019 to aid in its review.  Under the Paperwork Reduction Act (PRA), OMB must evaluate all new and (periodically) all existing federal government requests for information based on administrative burden. OFCCP originally published…
In its most recent status update, filed with the court as ordered by Judge Tanya S. Chutkan, EEOC is reporting it and NORC are on schedule to open the EEO-1 Component 2 pay data reporting tool on July 15, 2019. The status report explained that a Computer-assisted Web Interview (CAWI) data collection instrument will be available on July 15, 2019. Importantly, the report noted that NORC is working on a data file upload function…