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  • DOL Issues Final Rule Requiring Paid Sick Leave for Some Federal Contractor Employees
    by Cara Crotty - October 14, 2016
    On September 30, 2016, the U.S. Department of Labor (DOL) published its Final Rule to implement Executive Order 13706, Establishing Paid Sick Leave for Federal Contractors. President Obama issued the Executive Order on Labor Day 2015, and the Department of Labor issued a proposed Rule in February 2016. After receiving more than 35,000 comments, the DOL made very few substantive changes from the proposed Rule, and th...
  • OFCCP Issues Final Rule on Sex Discrimination
    by Cara Crotty - July 15, 2016
    The Office of Federal Contract Compliance Programs recently issued its Final Rule on Discrimination on the Basis of Sex. The new regulations rescind the OFCCP’s prior Sex Discrimination Guidelines and give regulatory effect to the latest interpretations of the law by the Equal Employment Opportunity Commission (EEOC) – including the EEOC’s interpretations of discrimination based on pregnancy and gender identity – a...
  • Will Your Organization Be Required to Provide Paid Sick Leave?
    by Cara Crotty - March 18, 2016
    On February 25, 2016, the U.S. Department of Labor published its Proposed Rule to implement Executive Order 13706, Establishing Paid Sick Leave for Federal Contractors. President Obama issued the Executive Order on Labor Day 2015, and the Department of Labor is required to issue final regulations by September 30, 2016. Individuals have 30 days, or until March 28, 2016, to submit comments on this proposal. The admi...
  • Don't Let Your Temporary Staffing Become a Permanent Headache
    by Cara Crotty - January 22, 2016
    Many federal contractors use outside staffing agencies to fulfill the labor demands of their workplaces – whether it is temporary staffing or recruiters for regular employees. While a valid and useful way to staff an organization, this practice can present several challenges for federal contractors who must comply with various recordkeeping requirements. The OFCCP’s regulations do not directly address this practice,...
  • by Cara Crotty - January 22, 2015
    The National Industry Liaison Group (NILG) routinely submits comments to proposed rules that affect the EEO and affirmative action obligations of federal contractors. The NILG Board believes that representing the views of our ILG constituents around the country in this manner is vital to achieving our mission and vision. Below is our comment to the OFCCP's Notice of Proposed Rulemaking on the Requirement to Report Summary...
  • by Cara Crotty - November 20, 2014
    As you have undoubtedly heard, the Office of Federal Contract Compliance Programs (OFCCP) released the revised versions of its Scheduling Letter and Itemized Listing on October 1, 2014. These documents advise federal “supply and service” contractors that the OFCCP has initiated a compliance review and set out the information required to be submitted to the agency. These new documents were effective immediately, and any c...
  • by Cara Crotty - September 26, 2014
    A hypothetical conversation with a frustrated and overwhelmed federal contractor Dear Cara: I work in human resources for a federal contractor, and I keep reading about President Obama’s executive actions directed towards federal contractors. We have a very small legal department in our company, and we are having a difficult time keeping track of all these new requirements. Can you please help us?!? Dazed &...
  • by Cara Crotty - April 29, 2014
    When thinking about the new developments in the OFCCP’s jurisdictional dispute with TRICARE network providers, the old adage about March weather came to mind. (The crazy spring weather we are experiencing probably also had something to do with prompting the analogy). In case you are not familiar with this ongoing saga, let me provide some history. OFCCP sues Florida HospitalThe OFCCP filed an administrative complaint agains...
  • by Cara Crotty - March 27, 2014
    Ever since the OFCCP issued its Final Rules implementing Section 503 of the Rehabilitation Act and the Vietnam Era Veterans’ Readjustment Assistance Act in September 2013, federal contractors have been concerned that the OFCCP will use the newly required collection of disability and protected veteran status from applicants as a tool to allege disparate impact on the basis of such protected status. This article will address th...
  • by Cara Crotty - January 30, 2014
    The Office of Federal Contract Compliance Programs issued its revised regulations implementing Section 503 of the Rehabilitation Act and the Vietnam Era Veterans’ Readjustment Assistance Act on September 24, 2013. Since then, contractors have had more questions than answers. What is troubling is the OFCCP’s apparent failure to think through many of the obvious issues now facing contractors, and instead of incorporating answe...