Helping individuals, companies, and organizations understand key legal and practical considerations for promoting compliance and making better business decisions in these types of federal, state, and local government contracting matters MORE

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Amy Conway

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On August 18, 2022, the Office of Federal Contract Compliance Programs (“OFCCP”) issued “Advancing Pay Equity Through Compensation Analysis,” a revision to Directive 2022-01, “Pay Equity Audits.” The revised Directive states that in order to determine that a contractor has satisfied its obligation to conduct a compensation analysis under 41 CFR § 60-2.17(b)(3), OFCCP requires certain documentation. Although the original Directive used the phrase “pay equity audit” to refer to contractors’ obligations under 41 CFR § 60-2.17(b)(3), this revised Directive instead uses the term “compensation analysis” to avoid any confusion regarding the nature of a contractor’s obligations.

Three things to know about the revised Directive:Continue Reading OFCCP Revises Directive on Pay Equity Audits / Compensation Analysis

Effective Compliance Evaluations and Enforcement

On March 31, 2022, the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) issued a new directive concerning enforcement of its equal employment opportunity laws. The new directive, DIR 2022-02, Effective Compliance Evaluations and Enforcement, provides updated guidance on agency compliance evaluation policies and expectations for…

As anticipated in our prior alerts, there have been continuing practical and legal challenges to implementing the Path Out of the Pandemic plan. This alert provides an update on the current status of challenges to OSHA’s Emergency Temporary Standard (ETS), Executive Order 14042 for federal contractors, and the Centers for Medicare and Medicaid Services (CMS)…

We have previously reported on implementation issues arising from President Biden’s Path out of the Pandemic plan, which included issuance of Executive Order 14042, Ensuring Adequate COVID-19 Safety Protocols for Federal Contractors, the related Safer Workforce Task Force Guidance, and Federal Acquisition Regulation (FAR) Class Deviations.

Since our last report, several legal developments warrant…

We have been answering a number of questions from clients regarding the nature and scope of the requirements for COVID vaccination, testing, masking and more. Our previous alert and blogs laid out the administration’s Path out of the Pandemic, the overarching directive outlining the federal government’s vaccination plan across government and industry sectors. This…