The OFCCP Digest - Produced by
Topic: OFCCP
During the last week of July 2018, the Department of Labor's Office of Federal Contract Compliance Programs (OFCCP) experienced a change in leadership. Director Ondray Harris stepped down after a short tenure with the agency, and Senior Advisor Craig Leen was installed as Acting Director...more
Bill Osterndorf
Bill Osterndorf
President and Founder, HR Analytical Services
Zach Olsen
Zach Olsen
Consultant, HR Analytical Services
Topic: OFCCP
As anticipated from Leen's conversations with contractors at the National Industry Liaison Group (NILG) conference in Anaheim, California during the first week of August 2018, the Office of Federal Contract Compliance Programs' (OFCCP) Directive 2018-04 plans to initiate "focused reviews"...more
Leigh Nason, Esq.
Leigh Nason, Esq.
Shareholder, Ogletree Deakins
Topic: AAP
The economy is going strong and the unemployment rate is at an all-time low. The last thing on anyone's mind is workforce downsizing or Reduction in Force (RIF). However, for the experienced Human Resources (HR) practitioner, s/he understands that RIFs do not occur solely during...more
Dan Kuang, Ph.D.
Dan Kuang, Ph.D.
Vice President - Legal and Audit Support,
Biddle Consulting Group, Inc.
Nina Le-Tse
Nina Le-Tse
EEO/AA Practice Manager - Data and Analytics, Biddle Consulting Group, Inc.
Topic: disability
In a new directive released on August 10, 2018, the Office of Federal Contract Compliance Programs (OFCCP) announced plans to start conducting focused reviews in the new fiscal year, which begins October 1st...more
Jenny Nelson
Jenny Nelson
Human Resources Senior Compliance Analyst, Goodwill Center for Work and Training – Southwest Campus
Ask the Experts
Ask the Experts is an online forum where federal contractors and subcontractors are invited to submit questions to industry experts related to OFCCP compliance, affirmative action planning, and equal employment opportunity. Simply register your company on to submit a question. Questions and answers will occasionally be featured in The OFCCP Digest for the benefit of all readers.
Question: Two-Week Posting Requirement
I've found it before, but having trouble on the OFCCP site finding the regulation that shows the requirement to post jobs for a minimum of two weeks. Can someone send me the link to that verbiage?
Answered by David Cohen from DCI Consulting:
Here is a link to the regulation that requires the job listing, but there is no requirement to list the job for two weeks: 60-300.5 Equal Opportunity Clause.
DOL Highlights
September 30 is the Deadline for VETS-4212 Reporting
Federal contractors and subcontractors with a contract of $150,000 or more are required to file an annual VETS-4212 report under the Vietnam Era Veterans' Readjustment Assistance Act of 1974 (VEVRAA). Employers must submit the VETS-4212 report by September 30, 2018, which covers the preceding 12-month period. You can find more details on the Department of Labor website, as well as a Frequently Asked Questions section related to VETS-4212 reports.
OFCCP Releases New Directives on Religious Exemption and Focused Reviews
Following similar pronouncements made by Acting OFCCP Director Craig Leen at the National Industry Liaison Group Conference in Anaheim, OFCCP recently issued two new directives.

Directive 2018-04, directs a portion of future OFCCP compliance reviews starting in Fiscal Year 2019, to include focused reviews on Section 503, VEVRAA, and E.O. 11246. A focused review is a comprehensive evaluation of a contractor's compliance with a specific regulation. For example, in a VEVRAA focused review, the OFCCP would go onsite to examine compliance related to equal employment opportunity and non-discrimination of protected veterans. VEVRAA requires compliance with the mandatory job listing requirement, including an EEO tagline in job postings, conducting outreach to veterans, setting a hiring benchmark, inviting applicants to self-identify as a protected veteran, data collection analysis, and performing an annual assessment of outreach efforts.

OFCCP also issued Directive 2018-03 which highlighted the religious exemptions within Executive Order 11246 and recent court decisions. It instructed OFCCP staff to keep these protections in mind when enforcing the Executive Order.
Job Accommodation Network Updates Website
The Job Accommodation Network (JAN) - the leading source for free, expert, and confidential guidance on workplace accommodations and disability employment issues - rolled out a redesigned website. The new, user-friendly design gives you easy access to a variety of resources, including training options, practical tools, and JAN's numerous articles and news.
OFCCP Releases "What Federal Contractors Can Expect"
The OFCCP released a two-page document describing "What Federal Contractors Can Expect," reflecting similar ideas Acting OFCCP Director Craig Leen expressed to the attendees at the National Industry Liaison Group conference. The OFCCP says it will focus on transparency, getting audits closed faster, and providing timely responses to compliance questions, among others.
Director of OFCCP, Ondray T. Harris, Steps Down
Less than eight months after becoming the Director of OFCCP, Ondray T. Harris has resigned from his position. The Department of Labor (DOL) gave no reason for Harris’ departure. Craig E. Leen, former OFCCP Senior Advisor, has taken over as the Acting Director.
Read more DOL Highlights throughout the month for timely updates.
The Institute for Workplace Equality is holding its 2018 Fall Compliance Conference on October 3rd and 4th in Denver, Colorado. Experts will touch on subjects including: New OFCCP leadership and enforcement priorities, paid leave laws, the latest on pay equity, and outreach. will be presenting on "The Essentials of Outreach to Veterans and Individuals with Disabilities." The conference will feature updates and highlights on important developments from the past year, as well as key focus areas for employers in 2019. Register online to attend the conference. 
OFCCP Update: Where We Were, Where We Are, and Where We're Going Webinar
Pay Equity Update: Do Your Pay Practices Make
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The OFCCP Digest is a complimentary resource featuring affirmative action, equal employment opportunity, and government compliance topics. Previous editions are available for easy reference on The OFCCP Digest Archives page. To subscribe or to provide feedback, email
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.