News & Analysis as of

Office of Federal Contract Compliance Programs Wage and Hour Regulatory Requirements

Seyfarth Shaw LLP

2021 EEO-1 Reports of Federal Contractors to be Released by OFCCP Absent Employer Action

Seyfarth Shaw LLP on

The University of Utah and a non-profit organization named "As You Sow" have issued FOIA requests to the Office of Federal Contract Compliance Programs (“OFCCP”) for the 2021 Type 2 Consolidated EEO-1 Reports filed by federal...more

Polsinelli

To Disclose or Not to Disclose: OFCCP to Appeal Adverse EEO-1 Report Disclosure Order

Polsinelli on

As previously reported, in late December 2023, the Northern District of California ordered OFCCP to release the EEO-1 reports of federal contractors it had previously withheld from production based on various exemptions under...more

Polsinelli

Federal Court Rejects Objections and Orders OFCCP to Disclose EEO-1 Reports

Polsinelli on

Despite objections by thousands of employers and its own continuing review of records, the OFCCP has been ordered by a federal court to produce all EEO-1 Type 2 reports of federal prime contractors and first-tier...more

DCI Consulting

[Webinar] Expert Summit for Employment Attorneys: OFCCP: Privileged vs. Proactive Analyses - February 21st, 2:00 pm - 3:00 pm EST

DCI Consulting on

In 2022, OFCCP issued a directive to advance pay equity through compensation analysis. During the original release of the directive, many in the legal community were concerned that OFCCP would require the production...more

Robinson+Cole Manufacturing Law Blog

Update: OFCCP Plans to Disclose EEO-1 Data for Non-Objecting Contractors Starting January 2023

As an update to our October 12, 2022 post regarding the deadline for federal contractors and first-tier subcontractors to object to disclosure of their Type 2 Consolidated EEO-1 reports from 2016 to 2020, the Office of...more

Robinson+Cole Manufacturing Law Blog

Deadline Fast-Approaching for Specific Contractors to Object to Type 2 EEO-1 Report Disclosure

In 2019, the Office of Federal Contract Compliance Programs (OFCCP) received an unprecedented Freedom of Information Act (FOIA) request from an investigative reporter (which was later amended), requesting Type 2 Consolidated...more

FordHarrison

Construction Contractors Seeking to Take Advantage of Infrastructure Bill: Beware of Federal Compliance Obligations

FordHarrison on

Construction contractors are scrambling to secure contracts funded by the $1 trillion Infrastructure Bill signed by President Biden on November 15, 2021. Although lucrative, those contracts come with extensive obligations and...more

Polsinelli

OFCCP May Use EEO-1 Data Reported By Employers in Support of Enforcement Efforts

Polsinelli on

On September 1, 2021, the Office of Federal Contract Compliance Programs (OFCCP) announced that it would “evaluate” using compensation data reported by federal contractors in annual EEO-1 filings to guide its enforcement...more

Proskauer - Government Contractor Compliance...

OFCCP to Reconsider Use of EEO-1 Component 2 Data

OFCCP announced on September 1, 2021 that it plans to rescind a November 2019 notice regarding EEO-1 Component 2 data. EEO-1 Component 2 data was required to be submitted in 2019, and consists of aggregated employee wage and...more

Littler

OFCCP Reverses Course, Will Use EEO-1 Pay Data for Investigation, Enforcement

Littler on

On September 1, 2021, the Office of Federal Contract Compliance Programs (OFCCP), the Department of Labor sub-agency charged with enforcing affirmative action and non-discrimination requirements imposed on federal contractors...more

Stinson - Government Contracting Matters

Updates on EEO-1 Reports, Non-Binary Self-Identification, and VETS-4212 Reports

EEO-1 Reports - With September upon us, many employers are remembering the prior filing deadline for EEO-1 Reports and wondering what is happening with that obligation. The short answer is that the U.S. Equal Employment...more

Seyfarth Shaw LLP

Seyfarth Policy Matters Newsletter - February 2020 #3

Seyfarth Shaw LLP on

NLRB Issues Final Joint Employer Rule. On February 26, the NLRB published its final rule governing joint employer status under the National Labor Relations Act. ...more

Stinson - Government Contracting Matters

End to EEO-1 Component 2 Pay Data Reporting for Now…

On February 10, 2020, in National Women’s Law Center v. Office of Management and Budget, the U.S. District Court for the District of Columbia ordered the Equal Employment Opportunity Commission’s (EEOC’s) collection of gender...more

Hogan Lovells

Pay Equity: Still a Growing Concern

Hogan Lovells on

Pay equity continues to be a complex and evolving issue for employers. Although the Equal Employment Opportunity Commission (“EEOC”) recently ended its Component 2 pay data collection, employers still face substantial...more

Carlton Fields

Construction Contractors Take Note: OFCCP’s Industry-Focused Technical Assistance Guide (TAG) May Prove Helpful in Preparing for...

Carlton Fields on

Federal construction contractors are barred from discriminating in employment on the basis of race, color, religion, sex, sexual orientation, gender identity, national origin, disability, or covered veteran status, and many...more

Smith Anderson

[Webinar] 2020 OFCCP Developments: What Federal Contractors Need to Know this Year - January 15th, 1:00 pm ET

Smith Anderson on

In 2019, OFCCP has been very busy increasing its enforcement activities and issuing policy changes. The agency also garnered a lot of attention for significant pay equity settlements and ongoing litigation. OFCCP continues...more

Littler

OFCCP Will Not Request, Accept or Use EEO-1 Component 2 Data

Littler on

The Office of Federal Contract Compliance Programs (OFCCP) has announced that it will not request, accept, or use “Component 2” compensation data submitted on the EEO-1 form....more

Littler

Something Old, Something New: Contractor Recognition and AAP Verification on the Horizon at OFCCP

Littler on

On August 24, 2018, the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) issued three new directives, 2018-05, 2018-06, and 2018-07. While directive 2018-05 has received most of the attention...more

Littler

OFCCP Reins in Compensation Analysis by Rescinding Directive 307 and Issuing New Guidance

Littler on

On August 24, 2018, the Office of Federal Contract Compliance Programs (OFCCP) rescinded Directive 307 and its Obama-era procedures for reviewing contractor compensation systems and practices, and replaced it with a new...more

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