August 25, 2019

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OFCCP Proposes Construction Compliance Check Letters

In furtherance of its work as an enforcement agency and its commitment to conduct reviews of more contractors, OFCCP posted in the Federal Register on Monday, April 8, 2019 its proposal for a series of compliance check audit letters for construction contractors. The agency is request feedback on two proposed construction compliance check letters  – federally assisted versus a direct federal contract.

OFCCP proposes those construction companies that hold direct federal contracts will be required to submit:

  • Personnel records that “list construction trade employment activity (applicants, hires, promotions, layoffs, recalls, voluntary terminations, and involuntary terminations), including the name, job classification, gender, race and/or ethnic designation for each employee or applicant”
  • Payroll records
  • Job advertisements,
  • Section 503 and VEVRAA affirmative action plans,
  • Section 44(k) veteran and disability analytics,
  • Requests for accommodations
  • Veteran hiring benchmark

The submission for federally assisted contractors would include only:

  • Personnel records that “list construction trade employment activity (applicants, hires, promotions, layoffs, recalls, voluntary terminations, and involuntary terminations), including the name, job classification, gender, race and/or ethnic designation for each employee or applicant”
  • Payroll records
  • Job advertisements
  • Requests for accommodations

Comments on the proposal are due on June 7, 2019.

Jackson Lewis P.C. © 2019

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About this Author

Laura Mitchell, Jackson Lewis, Management Representation lawyer, Contractual Drafting Attorney
Principal

Laura A. Mitchell is a Principal in the Denver, Colorado, office of Jackson Lewis P.C. She represents management exclusively in all areas of employment law, focusing on affirmative action and government contractor compliance.

Ms. Mitchell is a Principal in the firm’s Affirmative Action and OFCCP Defense practice group, representing government and non-government contractors in Office of Federal Contract Compliance Programs (OFCCP) matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming...

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