On February 22, 2012, the Equal Employment Opportunity Commission ("EEOC") approved a Strategic Plan for Fiscal Years 2012-2016, which included a directive to the EEOC to establish EEOC priorities and to integrate the agency's various responsibilities. Pursuant to that directive, the EEOC recently released a draft Strategic Enforcement Plan ("SEP") for public comment.

The draft SEP highlights five distinct national priorities: (1) eliminating systemic barriers in recruitment and hiring, specifically class-based intentional hiring discrimination and facially neutral hiring practices that have an adverse impact on certain groups; (2) protecting immigrant, migrant and other vulnerable workers; (3) addressing emerging issues, including interpretation and application of the ADA Amendments Act and LGBT (lesbian, gay, bisexual and transgender) coverage under Title VII; (4) preserving access to the legal system, including retaliation and overly-broad waivers; and (5) combating harassment.

Public comments are due by September 18, 2012, 5:00 pm EST and may be submitted by e-mail to strategic.plan@eeoc.gov. The SEP is set to take effect October 1, 2012, and will remain in effect through September 2016 (or until a new SEP is approved by the EEOC).