The Office of Federal Contract Compliance Programs (OFCCP) has issued its new Federal Contract Compliance Manual (FCCM) in an effort to provide its staff with the procedural framework necessary for quality and timely compliance evaluations and complaint investigations. One of the primary goals in issuing the new FCCM is to encourage uniformity among all OFCCP investigations nationwide. In addition, federal contractors will have access to the FCCM for guidance and assistance.
The FCCM is posted on the OFCCP’s website at www.dol.gov/OFCCP/. The Manual is over 500 pages in length and covers desk audits, onsite reviews, compliance evaluations, and complaint investigations, and includes sample forms, letters and notices. Federal contractors are encouraged to review the Manual to obtain a better understanding of the process followed by OFCCP staff during reviews and investigations. The revisions are the first major changes in ten (10) years.
Clearer Insight Into Agency Practice
OFCCP Director Patricia Shiu has stressed that the new Manual is consistent with her ongoing effort to provide clear and consistent guidance to OFCCP staff. Director Shiu further indicated the revised Manual will assist OFCCP investigators “do their job in a manner that reflects [the OFCCP’s] commitment to leveling the playing field for business and ensuring fundamental fairness for workers.” Although the Manual is not substantive agency policy and does not create new legal rights or requirements, it will provide clear insight into the process followed during investigations and reviews.
Understanding the impact of the new compliance initiatives of the OFCCP is important for companies which contract with the federal government and fall within the jurisdiction of the OFCCP. St. Louis employment law attorneys can be of to you in navigating through these compliance obligations.