It makes perfect sense for OFCCP to back off enforcement during such a perilous time for our country and contractors will appreciate some space to focus on critical needs to maintain operations.

However, it is important that contractors maintain a consistency in meeting their regulatory requirements. Annual Affirmative Action Planning efforts should continue as normal even when exemptions are in place. Record keeping and documentation efforts musts remain in place to avoid future gaps in required data processing.

In response to President Trump's declaration of a national emergency, OFCCP issued a National Interest Exemption memorandum to facilitate response efforts for COVID-19.

The three-month exemption and waiver extends to obligations under E.O. 11246, Section 503, and VEVRAA for all supply and service and construction contracts. However, the exemption does not apply to the processing of complaints of discrimination or contractor obligations to comply with other federal, state or local civil rights laws.

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