The OFCCP DigestLocal JobNetwork The OFCCP Digest
Lessons Learned from OFCCP FY 2016 Conciliation Agreements Without Press Releases
Topic: OFCCP Audits
In FY 2016, the Office of Federal Contract Compliance Programs (OFCCP) quietly settled twelve compliance reviews without a press release. This is unusual. Historically, OFCCP publishes a press release with each conciliation agreement. If you missed reading about these resolutions...more
Suzanne Keys, SPHR, SHRM-SCP Suzanne Keys, SPHR, SHRM-SCP
HR Consultant, Berkshire Associates Inc.
I Think My Company is a Federal Contractor and Has Regulatory Obligations - But Where Can I Look to Search for That Information?
Topic: AAP
Doing business with the United States federal government can be very lucrative, but it comes with a price. That price arrives in the form of reporting obligations, recordkeeping, outreach, and much more! Failure to comply with all applicable regulatory requirements can also have...more
Christopher J. Near Christopher J. Near
Of Counsel, Ogletree, Deakins, Nash, Smoak & Stewart, P.C.
Kiosha H. Dickey Kiosha H. Dickey
Of Counsel, Ogletree, Deakins, Nash, Smoak & Stewart, P.C.
Did You Know? OFCCP has Tools to Answer Your Questions - Part 2
Topic: OFCCP
In a previous article, we talked about the fact that the OFCCP has tools to answer your questions. So let’s continue that conversation with some more FAQs and tools on some of the most asked-about topics...more
Carla Irwin, Esq. Carla Irwin, Esq.
President, Carla Irwin & Associates, Inc.
How Companies Can Benefit from Hiring People with Disabilities
Topic: Disability
The most common question I am asked when I meet with a prospective employer is, “Can you help me to better understand the benefits to my company?” This is a legitimate question because, as we know, one of the primary purposes of a business is to be profitable. If it...more
Sheryl Letwat Sheryl Letwat
Consultant, Clearbrook
Ask the Experts

Ask the Experts is an online forum where federal contractors and subcontractors are invited to submit questions to industry experts related to OFCCP compliance, affirmative action planning, and equal employment opportunity. Simply register your company on to submit a question. Questions and answers will occasionally be featured in The OFCCP Digest for the benefit of all readers.

Question: Tracking Applicant Accommodations
Are federal contractors required to track/document reasonable accommodations made for applicants in order to comply with a potential OFCCP audit? If so, what is the best way to do this?

Answered by Carla Irwin from Carla Irwin & Associates, Inc.:
Number 20 of the Itemized Listing does include documentation of all requested accommodations and their resolution. That would include any accommodations requested by applicants. Here is a link to the itemized listing.

With regard to the best way to track and document the information, that is really dependent upon your recruiting process. In general, I would suggest identifying who is responsible for taking the requests at each stage of the recruiting/hiring process and creating a template/form for them to complete. Identify a centralized depository and review the documentation on a regular basis.

Executive Order Plans to Reorganize the Executive Branch and Federal Agencies

President Donald Trump issued a new Executive Order to reorganize the executive branch in an effort to improve accountability and efficiency. The order directs the Office of Management and Budget (OMB) to come up with a plan to reorganize governmental functions and eliminate unnecessary agencies. The plan shall include an invitation to the public to suggest improvements for the OMB to consider.

Senate Votes to Rescind the Fair Pay and Safe Workplaces Regulation

In a close vote, the U.S. Senate approved to repeal Executive Order 13673: Fair Pay and Safe Workplaces. The order, best known as the “Blacklisting” Rule, would require all federal contractors to publicly report labor violations. Last October, a Texas judge temporarily stopped the implementation of EO 13673, but the “paycheck transparency” provisions of the regulation still went into effect on January 1, 2017. Now the matter goes to President Trump, who is expected to sign the bill to formally stop the order. This would make Executive Order 13673 invalid and prevent its regulations and requirements from being implemented.

Non-Substantive Change to OFCCP Pay Transparency Provision

OFCCP recently added the Regulatory Citation (41 CFR 60-1.35c) to the Pay Transparency Nondiscrimination Provision. Each employer covered by Executive Order 11246 must post this provision and incorporate it in their employee handbooks or manuals. While this change to the provision is non-substantive, the National Industry Liaison Group (NILG) and OFCCP acknowledged that contractors should take action to apply the revised provision as soon as their business practices would allow.

OFCCP Distributes Corporate Scheduling Announcement Letters to 800 Establishments

On February 17th, OFCCP sent out 800 Corporate Scheduling Announcement Letters (CSAL) to 375 “distinct companies” across 29 industries. The CSAL gives these establishments advance notice of upcoming audits based on the list generated by the Federal Contractor Selection System (FCSS). The DOL website has an FAQ on items related to this particular round of CSALs. This was categorized as the “first release” of CSALs in 2017; however, there was no indication if or when another round of CSALs will be distributed. This is the first time since July 2014 that the OFCCP has issued CSALs.

Read more DOL Highlights throughout the month for timely updates.
Women's History Month

Women’s History Month, which is celebrated in March, recognizes the contributions of women in the workforce. As part of the celebration, the Department of Labor is sharing interesting facts and figures about the participation women in the US labor force. You can find more information on the DOL website.
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The OFCCP Digest is a complimentary resource featuring affirmative action, equal employment opportunity, and government compliance topics. Previous editions are available for easy reference on The OFCCP Digest Archives page. To subscribe or to provide feedback, email
The opinions expressed in this newsletter are the opinions of the individual author(s) and do not necessarily reflect the opinions of the Local JobNetwork™. The information appearing in this newsletter is meant to provide the reader with a general understanding of topics relating to OFCCP compliance requirements and is not legal advice. If you are seeking legal advice to address OFCCP compliance issues or requirements, you should consult an attorney. The Local JobNetwork™ expressly disclaims all liability with respect to actions taken or not taken based on any or all of the contents of this newsletter.