The OFCCP Digest Local JobNetwork The OFCCP Digest Bill Osterndorf Scott Pechaitis, Esq. and Lisa Marsh, Esq. Chris Lindholm Marilynn Schuyler, Esq. Diana Younts
OFCCP’s Jurisdictional Thresholds
by Bill Osterndorf

In the last few years, there have been many changes to the way that the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) implements the federal affirmative action regulations. The agency has issued many new and revised regulations that have affected organizations throughout the United States. OFCCP has taken some particularly aggressive positions in regard to discrimination that it believes is occurring involving...more

Bill Osterndorf William A. Osterndorf is President and founder of HR Analytical Services and has been working with affirmative action/equal opportunity issues for the last 25 years in the public and private sectors. Bill specializes in developing and writing affirmative action...more

Do Your Job Descriptions Hold Up in the New Era of Federal Contractor Enforcement?
by Scott Pechaitis, Esq. and Lisa Marsh, Esq.

With the flurry of changes and ever-expanding obligations for federal contractors over the last eighteen months, employers have undoubtedly spent countless hours and resources “getting into compliance” and updating documents and forms. With each new obligation, employers have reviewed and altered everything from job advertisement taglines and purchase orders to online applications and self-ID forms.

Yet with all of these required changes, there is one important document that federal contractors have likely neglected – the job description. While there are no new regulations explicitly requiring changes to job descriptions (in fact, there is no law requiring...more

Scott Pechaitis, Esq. Scott Pechaitis is a Shareholder in Jackson Lewis' national Affirmative Action & OFCCP Defense practice group. He works closely with Jackson Lewis' in-house...more

Lisa Marsh, Esq. Lisa Marsh is an attorney in Jackson Lewis’ national Affirmative Action & OFCCP Defense practice group. She represents management exclusively in all...more

Compensation Compliance
by Chris Lindholm

For many years, compensation compliance has been discussed ad nauseam in Industry Liaison Group (ILG) meetings, webinars, and in articles by the hundreds that included topics on OFCCP expectations/enforcement, data collection and suggested analyses. In related fashion, EEO/AA professionals have attended the National Industry Liaison Group (NILG) conference held in various major cities in the U.S. each year for a few decades now and every year...more

Chris Lindholm Chris Lindholm has 18 years of experience in Affirmative Action Planning and EEO consulting, which includes OFCCP audit support, risk management, training, and software development. Since 1997, Chris has supported thousands of...more

The New Pay Transparency Final Rule – A Sea Change for Workplace Culture
by Marilynn Schuyler, Esq.

The workplace culture of federal contractors is about to change dramatically. It has been taboo in the private sector to discuss one’s personal salary or inquire about the compensation of others, but the recently issued Pay Transparency Final Rule will provide protections to applicants and employees who break tradition...more

Marilynn Schuyler, Esq. Marilynn L. Schuyler has been developing Affirmative Action Plans for public, private, and academic institutions since 1996, and has been working in the field of Equal Employment Opportunity since 1988. She provides clients with...more

Revisiting VEVRAA - What Should Contractors Be Doing?
by Diana Younts

President Gerald Ford passed Section 4212 of the Vietnam Era Veterans' Readjustment Assistance Act of 1974 (VEVRAA) on December 4, 1974, which was originally created for veterans returning home from the Vietnam War. This was necessary because - generally speaking - society was biased against the war and the military men and women who served in Vietnam...more

Diana Younts Diana Younts is a subject matter expert on affirmative action and equal opportunity. She has a B.A. in Behavior Sciences and a certificate in mediation. Diana is a member of the Atlanta Society of Human Resources Management (SHRM), Metro Atlanta Chamber, and Cobb Chamber of...more



OFCCP Develops a Reasonable Accommodation Pocket Card
OFCCP created a pocket card “Requesting a Reasonable Accommodation” to help applicants, employees, and other interested parties understand the process of requesting a reasonable accommodation.

Submit Feedback About VETS-4212 Report
The Veteran Employment and Training Services (VETS) is soliciting feedback from Industry Liaison Group (ILG) members regarding the VETS-4212 filing process. If your organization submitted a VETS-4212 report this year, consider sharing your feedback with VETS by filling out this survey. The deadline to submit feedback is Tuesday, October 27, 2015.

EEO is the Law Supplement
OFCCP posted an “EEO is the Law Supplement Poster” on its website. The supplement poster is applicable to federal contractors and subcontractors. OFCCP does not state when the poster needs to be posted; however, it is a mandatory supplement of the “EEO is the Law” poster. OFCCP provides guidance on how to use the supplement in its FAQs until the revised “EEO is the Law” poster is released.

Read more DOL Highlights throughout the month for timely updates.



National Disability Employment Awareness Month (NDEAM), held each October, is a time to celebrate the many and varied contributions of individuals with disabilities who work throughout America. This observance dates back to 1945 and was recently recognized with a Presidential Proclamation by President Obama.

In conjunction with this celebration, OFCCP posted a new video, Disability Inclusion Starts With You. The video addresses why companies doing business with the federal government ask job applicants and employees to voluntarily self-identify any disability, and explains that self-identification helps ensure equal opportunity for all people with disabilities.

The Office of Disability Employment Policy (ODEP) offers these ideas to increase awareness for employers and employees. The theme of this year’s observance should be remembered each and every day, “My disability is one part of who I am. At work, it’s what people can do that matters."

LJN Radio
OFCCP Compliance
Government Compliance
Unemployment Status Discrimination and OFCCP Enforcement OFCCP: Friend or Foe?

Ahmed Younies, President and CEO of HR Unlimited, Inc., shares his surprising perspective on how employers should approach being a federal contractor and subcontractor.

Ask The Experts Webinar
Join LocalJobNetwork.com, Carmen Couden, Attorney at Foley & Lardner LLP, and Bill Osterndorf, President of HR Analytical Services as we answer your questions regarding compliance.

"Ask the Experts" is a Q&A panel webinar where we answer a spectrum of questions regarding compliance. The webinar is different than the typical webinar format because we are going directly into the Q&A session, which gives human resource professionals, compliance specialists, and the like access to the pressing questions they need answered.

Making History: A DOL Fast Fact

Appointed by President Franklin Roosevelt, Frances Perkins is the first woman appointed to a Cabinet of the United States. She was the longest serving Secretary of Labor (March 4, 1933 – June 30, 1945) and was the principal architect of the Social Security Act. She accomplished all but one of her goals that she presented to President Roosevelt in 1933: universal access to health care. In 1980, the Department of Labor headquarters in Washington, D.C. was named after Frances Perkins.



The OFCCP Digest is a complimentary resource featuring affirmative action, equal employment opportunity, and government compliance topics to help federal contractors and subcontractors navigate the regulatory environment. Your feedback is important to us. Please share your thoughts about The OFCCP Digest by taking
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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.