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9/26 OFCCP Town Hall Meeting

Friday, September 29, 2017   (0 Comments)
Posted by: Michael Pati
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On September 26, the Office of Federal Contract Compliance Programs (OFCCP) held the second of three scheduled town hall meetings in San Francisco. According to the OFCCP, the purpose of these meetings is to “enhance the scope and quality” of its Compliance Assistance Program which aims to help federal contractors comply with the requirements of Executive Order 11246, VEVRAA and Section 503 of the Rehabilitation Act. The meeting was attended by Acting Interim Director Thomas Dowd and other OFCCP personnel, federal contractors and subcontractors from a variety of industries, as well as consultants and attorneys.

In his opening remarks, Mr. Dowd reminded attendees of OFCCP’s two main goals which are, to determine that contractors are meeting their regulatory obligations voluntarily; and to resolve all matters that may arise during a compliance review without going through litigation.

To support those goals, the information gathered at the town hall meetings are meant to bolster OFCCP’s compliance assistance efforts not only by potentially helping to improve the information and materials they offer, but also through a willingness by the Agency to address some of the perceived challenges in recent years with its relationship with the contractor community. As such, rather than offering scripted presentations to the audience, the OFCCP has designed these meetings for the purpose of gathering the views and learning about the experiences of federal contractors in implementing and managing their equal employment opportunity and non-discrimination obligations.

After the opening remarks, Mr. Dowd invited the attendees to divide into small groups and asked them to provide feedback on the following questions:

1) What are some creative and/or innovative ways of making OFCCP’s compliance assistance more practical?

2) What are some new ways OFCCP can make compliance assistance more collaborative?

The answers generated by the small groups during these brainstorming sessions were then shared and discussed with everyone. The ideas found to be most popular by the attendees include:

  • Offering online resources (e.g., webinars, webcasts, white papers, etc.) to share best practices for large and small contractors, as well as top violations identified during compliance reviews.
  • Creating a comprehensive library of examples of required documentation, such as the notification letter to subcontractors/vendors of their obligation to comply with AA regulations, AAP policy statement, results of the contractor’s effectiveness of its outreach and recruitment efforts, and actions taken to comply with audit and reporting system requirements.
  • Improving the method of collecting the correct contractor’s contact information when issuing the Corporate Scheduling Announcement Letters (CSALs) so that they may be delivered to the appropriate personnel on a more timely basis.
  • Periodically posting online the list of contractors who have been sent the CSALs and/or who are in the pool who may be selected for Compliance Reviews.
  • Redesigning the OFCCP website for easier navigation, especially for new contractors, to find information on the regulations and AAP requirements.

In addition, Director Dowd made an effort to reassure attendees several times that compliance reviews are “neutrally scheduled” and contractors who happen to take advantage of OFCCP’s compliance assistance would not be selected for audits simply as a result of utilizing those services. He also encouraged contractors to escalate any problems or concerns through the appropriate district and, if necessary, regional chain-of-command if they may be having a poor experience with the compliance officer handling their audit.

The last of the three town hall meetings occurred on September 28th in Chicago. Mr. Dowd will be heading back to the National Office and meet with members of his team to discuss strategies to implement change as they weigh the legal, regulatory, logistical and budgetary challenges they currently face. Attendees found the candor with which Mr. Dowd expressed his and the OFCCP’s interest and willingness to listen to all suggestions and requests to improve the agency’s compliance assistance program, as well as their desire to strengthen its relationship with contractors, a welcome change.


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