Category Archives: Office of Federal Contract Compliance Policy

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Playing Cards With a Government That Stacks the Deck – D.C. District Court Radically Expands The “Christian Doctrine” To Subcontracts

By David Gallacher On March 30, 2013, the U.S. District Court for the District of Columbia issued a decision imposing certain socio-economic contract requirements on subcontractors operating hospitals associated with the University of Pittsburgh Medical Centers. See UPMC Braddock, et al. v. Harris, Civ. 09-1210 (PLF) (D.D.C. Mar. 30, 2013) (“UPMC Braddock”). Even though the … Continue Reading

The DoD IG Has Moved

The Office of the Inspector General of the Department of Defense recently changed its mailing address. Unfortunately, some contractors have failed to notice the change, and have used the old address in attempting to submit their disclosure letters. Unfortunately, these disclosures were returned to sender. The new address(es) are below, and detailed information can be … Continue Reading

OFCCP’s FAAP Rule Revision Places More Burdensome Requirements on Contractors

By Nick Schnermann and Ryan Roberts On July 14, 2011, the Office of Federal Contract Compliance Programs’ (“OFCCP”) proposed rule implementing Executive Order 11246 became final. See 41 C.F.R. 60-2.1(d)(4). The new rule updates the procedures whereby a contractor submits both initial and renewal applications to obtain OFCCP approval for its Functional Affirmative Action Program (“FAAP”). These revisions … Continue Reading

OFCCP’s Proposed Equal Employment Opportunity Rules: More On-Site Investigations, More Data Collected From Contractors, Closer Scrutiny of Contractor Affirmative Action

By W. Bruce Shirk and Nick Schnermann The Office of Federal Contract Compliance Programs (“OFCCP”) recently proposed two rules that would, among other things, enhance the agency’s investigative and enforcement capabilities and substantially increase the amount of EEO-related data it will collect from contractors. These proposals should come as no surprise – OFCCP’s publicly available budget … Continue Reading

OFCCP Investigations Likely to Rise

By Richard Siegel Two recent policy changes announced by the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (“OFCCP”) likely will lead to a significantly greater number of and increased scope for investigations conducted by that Office into allegations of discrimination and pay disparity against Government contractors.  … Continue Reading

Department Of Labor Attempts To Extend The “Christian Doctrine” To Subcontracts

By W. Bruce Shirk and Anne B. Perry It has long been questioned whether the “Christian Doctrine,” pursuant to which mandatory contract clauses reflecting core procurement policy are incorporated into government prime contracts by operation of law, can be used to incorporate such clauses into subcontracts. That question may now have an answer. In a non-CDA decision issued … Continue Reading
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