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During Financial Town Hall OFCCP Shares Upcoming Initiatives


OFCCP discussed six initiatives ranging from ways to check for AAP compliance to developing a tool to help contractors develop pay analysis groups

On April 9, 2019 OFCCP hosted a town hall meeting in New York focused on the financial industry. OFCCP’s goal was to provide contractors in this sector the opportunity to share their views on what the agency can do to help contractors. OFCCP was also seeking ideas on how to improve diversity and inclusion in the financial and related fields.

OFCCP sought feedback on the following questions.

• How financial firms have approached diversity and inclusion.

• How they have addressed the low numbers of women and minorities at their highest levels.

• How they can create and implement parental and family leave program.

• How OFCCP can help the firms with diversity hiring.

• How it can support disability inclusion programs.

OFCCP Director Craig Leen shared information about the agency’s upcoming initiatives.

  1. AAP Verification Initiative, Directive 2018-07, already in effect, whereby OFCCP has added AAP compliance in a number of its processes, as follows:

o Requiring the submission of the E.O. 11246 AAPs during a Section 503 focused review.

o Not granting extension to scheduling letters

o During reviews, checking the SAM database to see if the contractor answered the annual AAP preparation inquiry and check data against answers to root out discrepancies.

o OFCCP is working on a collection effort where contractors will be required to certify AAP compliance and possibly submit AAPs annually to OFCCP through a web portal. This initiative would be required to go through notice and public comment and receive approval from the OMB.

  1. OFCCP is preparing a new guidance tool that focuses on how to form pay analysis groups.

  2. OFCCP is focusing on promotions in an effort to increase the number of women in senior roles. To accomplish this, OFCCP will create new focused reviews on promotions of women and women of color. Leen shared his concern that inequitable parental leave policies may hinder women from advancing in the workplace.

  3. OFCCP wants to reduce the length of audits over the next two to three years. Leen said that the average length of desk audits is now approximately 30 days, down from over 100 days. He wants to shorten the time used for conciliation efforts which he feels should last no longer than six months.

  4. The OFCCP online help desk and opinion letters should be available “soon” as OFCCP is about to release its first opinion letter, modeled after the Wage and Hour letters.

  5. OFCCP is considering some new recognition programs, possibly for FAAPs and for contractors that demonstrate a strong commitment to compliance during audits.

The participants of the town hall urged Leen to hire more staff with private-sector experience; however, he stated that many of their labor economists worked in the private sector. He then went on to dispel the idea that the agency was out of touch with the contractors that it regulates. He stated “Our goal is not to change how a company pays people, not to change their compensation system.” “Our goal is to make sure whatever they set up is not causing discrimination, and to the extent it is, that has to be corrected both going backwards and forwards.”

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