We appear to be on the precipice of another federal government shutdown. Absent a political compromise, the federal government’s funding will run out on September 30, 2023. During previous government shutdowns, government agencies and departments issued stop-work orders, grinding work on
Government Contractor Compliance & Regulatory Update
The Government Contractor Compliance & Regulatory Update blog, published by Proskauer Rose LLP, focuses on legal developments affecting federal contractors and subcontractors. It covers regulatory changes, compliance requirements, and enforcement actions related to government contracts, including labor and employment issues, affirmative action obligations under laws like Section 503 and VEVRAA, and implications of government shutdowns. The blog also addresses emerging topics such as the impact of executive orders on diversity, equity, and inclusion (DEI) initiatives, the use of artificial intelligence in the workplace, and federal investigations into civil rights compliance. It provides guidance on navigating complex federal regulations and managing risks associated with government contracting.
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VETS-4212 Deadline Quickly Approaching: File by September 30, 2023
As we previously posted, federal contractors and subcontractors meeting the VEVRAA eligibility threshold (“Covered Contractors”) have until September 30, 2023 to file their VETS-4212 Reports.
Covered Contractors are “recommend[ed]” to file the form electronically, but they can email or physically…
OFCCP Announces New Round of Contractors Selected for Audits – Was Your Company Selected?
By Guy Brenner
On September 8, 2023, OFCCP announced it posted a new Corporate Scheduling Announcement List (CSAL) for supply and service contractors. OFCCP announced that the list consists of 1,000 federal contractors and subcontractors selected for a Compliance Review (Establishment Review), Corporate…
Significantly Expanded OFCCP Scheduling Letter and Itemized Listing Now In Effect
Updated: September 2, 2023.
On August 25, 2023, OFCCP announced the implementation of its revised Combined Scheduling Letter and Itemized Listing, which “applies to supply and service compliance evaluations scheduled on or after August 24, 2023.” The documents are…
OFCCP Publishes Rule Modifying Pre-Enforcement Notice and Conciliation Procedures
On August 4, 2023, OFCCP published its final rule, “Pre-Enforcement Notice and Conciliation Procedures” (the “New Rule”) which “modif[ies] procedures and standards [OFCCP] uses when issuing pre-enforcement notices and securing compliance through conciliation.” In a blog post, OFCCP Acting…
OFCCP Acting Director Addresses OFCCP Priorities and Initiatives
Speaking at the annual NILG conference, on August 2, 2023, OFCCP Acting Director Michele Hodge addressed hundreds of attendees in a wide ranging speech, discussing the agency’s priorities and initiatives. Among other highlights of her address:
- Acting Director Hodge
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Contractors: VETS-4212 Filing Window Now Open Until September 30, 2023
Federal contractors and subcontractors meeting the VEVRAA eligibility threshold of having 50 or more employees and at least one federal contract totaling $150,000 or more (“Covered Contractors”) must annually file a VETS-4212 Report. The VETS-4212 filing period is now open,…
FAR Council Bans TikTok from Federal Contractor Devices
On June 2, 2023, the Federal Acquisition Regulation (FAR) Council published an interim rule which requires contracting officers to insert a new clause – FAR 52.204-27 – in solicitations after June 2, 2023 or when exercising an option or modifying…
Reminder: Contractors Must Begin Using Updated Voluntary Self-ID Form by July 25
As we previously reported, OFCCP’s updated Voluntary Self-Identification of Disability Form (CC-305) was approved by the Office of Management and Budget (OMB) in April 2023. Form CC-305 was updated to include “the preferred language for disabilities and… additional examples…
Reminder: Deadline for Contractors To Certify AAP Compliance is June 29, 2023
As we previously reported, federal contractors and subcontractors (“Contractors”) have until June 29, 2023 to certify the status of their Affirmative Action Programs (“AAPs”) with the OFCCP Contractor Portal. Specifically, covered Contractors are asked to certify, on an…