The third of the three Directives OFCCP issued last Friday, Directive 2018-06 “Contractor Recognition Program” announces a program by which OFCCP will recognize contractors with “high-quality and high-performing compliance programs and initiatives.” Recognition is one of the four themes Acting Director Leen has spoken about recently and such programs are not a new concept in the Agency – some of you may recall OFCCP’s previous EVE Award program. The Agency’s new Directive, however, describes a program having much more potential than a simple recognition program.

While the Directive is short on specific details for the program, it shows OFCCP is looking for creative and more effective ways to encourage voluntary compliance and further the core principles of affirmative action. In furtherance of the Agency’s efforts to efficiently and effectively “expand its compliance reach,” the heart of the Directive is the idea that contractors can, and should, learn from one another regarding effective AAP efforts. The program would advance OFCCP’s compliance assistance efforts by identifying contractors with “innovative programs” driving “demonstrable results” that “could be taught or incorporated into contractor peer mentoring programs.”

OFCCP believes contractors would be supportive of a compliance assistance model that includes a peer-to-peer mentoring type component because OFCCP found contractor believe

other businesses best understand their compliance barriers and challenges.

The program will not simply recognize compliant contractors “but would be for contractors that are innovative thought leaders among their peers for achieving diverse and inclusive workplaces.” OFCCP would take the first step of identifying and approving “implementable best or model contractor practices,” and presumably establish a foundation and framework for a mentoring program through which contractors could expand and build upon the successes of their peers.

Collaboration is also central to this proposed program in another aspect. Rather than working alone, OFCCP promises to work directly with other federal entities, such as “the Women’s Bureau, the Office of Disability Employment Policy, and other Department of Labor components as appropriate.”