When OFCCP issued its “Town Hall Action Plan ” in May 2018, it stated its commitment to “review and enhance contractor compliance assistance materials.” In furtherance of this commitment, on August 2, 2019, OFCCP announced the publication of a number of new compliance assistance guides for contractors. These new resources are:
- Posting and Notices Requirements Guide – a guide focusing on posting and notice requirements for federal contractors. The document is a resource providing contractors with guidance about the information they must include in subcontracts and purchase orders, job advertisements, in the workplace, and to unions, as well as checklists for supply and service and construction contractors to help them manage these requirements. The document helpfully identifies the various contract value thresholds which trigger different notice and posting requirements. Contractors should be aware that this document appears focused solely on OFCCP posting and notice requirements, and that their contracts likely contain other posting requirements not covered by this document.
- Recordkeeping Guides – OFCCP has created three recordkeeping charts, providing contractors with at-a-glance reference materials regarding their recordkeeping obligations under Executive Order 11246 (race and sex), Section 503 (individuals with disabilities), and VEVRAA (protected veterans). The documents show not only the records that must be maintained, but also the length of time they must be retained.
- What Federal Contractors Can Expect – a republication providing contractors with “the general expectations that often guide interactions between federal contractors and OFCCP,” which we wrote about in August 2018.
OFCCP’s website also indicates OFCCP is working on technical assistance guides for supply and service and construction contractors.
The new materials reflect a tangible step by OFCCP to fulfill one of its Town Hall Action Plan commitments. Contractors should find the materials helpful for answering basic compliance questions.