Candee and John have completed their annual “deep dive” into OFCCP’s enforcement stats and Conciliation Agreements. While the failure to hire and compensation results are well-known, we are now able to give you a complete “blueprint”, mapping all of OFCCP’s alleged violations. This year is surprising in that both the volume of affirmative action plan alleged violations is very large and the alleged violations are also very broad in their scope. Gone are the days OFCCP had its favorite list of a few alleged violations and strayed not too far from that menu. OFCCP’s appetite for violations has clearly broadened. Candee’s and John’s “map” of the affirmative action plan violations, in addition to the alleged discrimination analyses, will position you for next year to know what parts of your AAPs you should put “under the microscope” and what repairs you should consider. Here is your chance to learn about OFCCP’s broadened compliance areas currently of interest to OFCCP.
Given the many new alleged violations to discuss, this will be a quick moving session with time for Q&A at the end.