Volume 4, Issue 4
The OFCCP Digest Local JobNetwork The OFCCP Digest Carmen Couden, Esq. Cara Yates Crotty, Esq. Debra Milstein Gardner Dr. Hossein Borhani Sandra Zeigler, Esq.
There's More Than Equal Pay On The Presidential Agenda This Year
by Carmen Couden, Esq.

Earlier this month, President Obama proclaimed April 8, 2014 to be National Equal Pay Day – the day that indicates how far into 2014 a woman must work in order to earn the same amount that men did in 2013. On the heels of that proclamation, President Obama issued a presidential memorandum directing the Department of Labor ("DOL") to propose rules that will require federal contractors and subcontractors to submit summary read more

Bill Osterndorf Carmen Couden, Esq. is senior counsel with Foley & Lardner LLP. She is a member of the firm's Labor & Employment Practice and Automotive Industry Team. As part of her practice, read more

OFCCP TRICARE ENFORCEMENT: In Like a Lion, Out Like a Lamb?
by Cara Yates Crotty, Esq.

When thinking about the new developments in the OFCCP's jurisdictional dispute with TRICARE network providers, the old adage about March weather came to mind. (The crazy spring weather we are experiencing probably also had something to do with prompting the analogy). In case you are not familiar with this ongoing saga, let me provide some read more

Cara Yates Crotty Cara Crotty, Esq. is a partner at Constangy, Brooks & Smith, LLP who has defended employers in cases involving every aspect of the employment relationship, including read more

Multi-Prong Approach to Changing the Culture of Self-Identifying as an IWD
by Debra Milstein Gardner

Before we can expect individuals with a disability to openly communicate, through the self-identification process, their disability and possibility a need for an accommodation, we must show them that the information will not be viewed or used in a negative way. In order to do this, we must take a multi-prong approach of education and communication, both externally and internally, within the organization. read more

Ahmed Younies Debra Milstein Gardner founded Workplace Dynamics LLC as a women-owned and operated human resources consulting firm in 1990. Debra has 33 years of experience gained read more

OFCCP's Impact Ratio Analysis (IRA) - Can it be Improved?
by Dr. Hossein Borhani

On page 48 of the July 2013 Federal Contract Compliance Manual (FCCM) the OFCCP describes its methodology for calculating the impact ratio and how the compliance officers (CO) are supposed to use the results of the impact ratio analyses:

Although related, a CO must not confuse adverse IRAs with the read more

Ahmed Younies Dr. Hossein Borhani is a Director at ERS Group's San Francisco office and leads its West Coast Labor and Employment practice. Dr. Borhani has testified as an expert witness in court and other judicial settings. read more

Similarly Situated in Compensation
by Sandra Zeigler, Esq.

In hiring, termination and promotion cases, the analysis examines each step of the decision making process to determine who should have been equally likely to be selected for the particular employment event. For example, in hiring at each stage you look at who remained eligible to progress to the next stage. Ultimately, the investigation should arrive at the final stage where selection rates of the remaining eligible individuals (the refined read more

Sandra Zeigler Sandra Scott Zeigler, Esq. is a recognized authority on Federal EEO enforcement with 25 years of experience divided equally between the EEOC and OFCCP. She was only the third read more

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OFCCP Compliance
Government Compliance
Unemployment Status Discrimination and OFCCP Enforcement The Importance of Who is Similarly Situated

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The OFCCP Digest is a complimentary resource for those who do business with the Federal government. Industry leaders throughout the country share their expertise on a range of topics including affirmative action, equal employment opportunity, and government compliance.

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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.