The OFCCP Digest Local JobNetwork The OFCCP Digest Chris Lindholm Carmen Couden, Esq. Bill Osterndorf Ahmed Younies Dr. Hossein Borhani
Choosing an Affirmative Action Plan Structure
by Chris Lindholm

In a time of changing laws and a pervasive fear of OFCCP audits, it is always a good idea to make sure that people have a good understanding of the basics in compliance and how internal decisions affect Federal contractors. For decades contractors have told me that when it comes to affirmative action “A plan is a plan is a plan,” meaning they are basically cookie-cutter reports and all AAPs are basically the same. At the same time, contractors have always... more

Chris LindholmChris Lindholm has 18 years of experience in Affirmative Action Planning and EEO consulting, which includes OFCCP audit support, risk management, training, and software development. Since 1997, Chris has supported thousands of... more

The OFCCP's Proposed Regulations on Sex Discrimination and What They Mean for Contractors
by Carmen Couden, Esq.

On January 30, 2015, the Office of Federal Contract Compliance Programs (“OFCCP”) published its proposed rule regarding updates to the current guidelines governing discrimination on the basis of sex. According to the OFCCP, the proposed changes will not... more

Carmen Couden, Esq. Carmen Couden, Esq. is senior counsel with Foley & Lardner LLP. She is a member of the firm’s Labor & Employment Practice and Automotive Industry Team. As part of her practice, Ms. Couden represents employers in investigatory proceedings.... more

Tips on Responding to New Scheduling Letter and Itemized Listing
by Bill Osterndorf

When the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) begins an affirmative action compliance review, it sends the organization subject to the review a letter that requests various types of information. This letter is referred to as a “scheduling letter.” The scheduling letter includes an itemized... more

Bill Osterndorf William A. Osterndorf is President and founder of HR Analytical Services and has been working with affirmative action/equal opportunity issues for the last 25 years in the public and private sectors. Bill specializes in... more

President Obama and the OFCCP: Looking Ahead to 2015 and Beyond – Part III
by Ahmed Younies

In our last two posts, we examined key actions taken by the OFCCP in 2014 through the lens of President Obama’s ambitious agenda. While some OFCCP actions have reflected Mr. Obama’s priorities, others have actually resulted directly from Executive Orders. Between the OFCCP’s actions, Mr. Obama’s Executive Orders and statements of his... more

Ahmed Younies Ahmed Younies has built human resources infrastructures for small-size companies as well as for mid-size to Fortune 500 companies. He has worked for the Office of Federal Contract Compliance Programs (OFCCP), enforcing compliance... more

A Quick Look at the OFCCP’s Enforcement Data for Fiscal Year 2010 to 2015 – Part II
by Dr. Hossein Borhani

In the previous part of this article (Part I), I reviewed some of the enforcement data the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has made available to the public. The data can be accessed here. It is provided in two parts; one dataset that consists of closed Compliance Evaluations and... more

Dr. Hossein BorhaniDr. Hossein Borhani is a Director at ERS Group's San Francisco office and leads its West Coast Labor and Employment practice. Dr. Borhani has testified as an expert witness in court and other judicial settings. Dr. Borhani’s work has included statistical... more



Help OFCCP Shape Smarter Regulations

The Department of Labor (DOL) issued a press release on March 13 stating that they are reviewing existing regulations to update rules that could be out of date, ineffective, insufficient, or burdensome to contractors. Through an interactive “Shaping Smarter Regulations” website, the DOL is asking the public for ideas about which rules should be modified, streamlined, expanded, or even repealed. The open suggestion period will end on April 1, 2015.


Stay up to date on the implementation of regulations from the Office of Federal Contract Compliance Programs (OFCCP) at the annual ILG National Conference in New York City. This event brings Affirmative Action practitioners, the legal industry, government agencies, human resource professionals, and industry experts together to learn about the regulatory agenda of OFCCP and EEOC, and to learn about the steps needed to meet the latest compliance requirements. Don’t delay – make plans to attend today. Learn more here.



Vocational Rehabilitation (VR) Programs are a state-federal partnership designed to help people who have physical or mental disabilities prepare for, find, or keep employment. Gaining skills needed for a career, learning how to prepare for a job interview, or getting the accommodations needed to stay employed are just a few of the ways this program helps people with disabilities increase productivity and independence. VR programs rely on a broad coalition of partners, vendors, and contractors to provide services to disabled individuals. You can find a nationwide directory of VR agencies here.

OFCCP Compliance Webinar OFCCP Compliance Webinar

Making History: A DOL Fast Fact

With only a few hours remaining in his presidency, President William Howard Taft signed the Organic Act – which created the U.S. Department of Labor (DOL) – on March 4, 1913. After Woodrow Wilson assumed the office of the presidency, he appointed William B. Wilson (a non-relative) as the DOL’s first secretary of labor.

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The OFCCP Digest is a complimentary resource for those who do business with the Federal government. Industry leaders throughout the country share their expertise on a range of topics including affirmative action, equal employment opportunity, and government compliance.

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The opinions expressed in this newsletter are the opinions of the individual author(s) and do not necessarily reflect the opinions of the Local JobNetwork™. The information appearing in this newsletter is meant to provide the reader with a general understanding of topics relating to OFCCP compliance requirements and is not legal advice. If you are seeking legal advice to address OFCCP compliance issues or requirements, you should consult an attorney. The Local JobNetwork™ expressly disclaims all liability with respect to actions taken or not taken based on any or all of the contents of this newsletter.