The Office of Federal Contract Compliance Programs (OFCCP) has announced that it will hold an online information session to discuss its new Active Case Enforcement (ACE) protocol, the process by which the agency conducts supply and service (S&S) compliance evaluations. In December 2010, the OFCCP issued a directive discontinuing the former Active Case Management (ACM) process that had been in place since 2003. Two months later, the agency issued a second directive outlining the new ACE procedures for conducting S&S compliance evaluations, which includes full desk audits, increased onsite evaluations, focused evaluations, and full reviews.
According to the webinar invitation, OFCCP representatives will explain what contractors can expect when scheduled for a S&S compliance evaluation using ACE procedures, including a discussion of key terms and how ACE procedures differ from the discontinued ACM process.
Attorneys in Littler’s OFCCP Practice Group have observed that under the new ACE procedures, contractors are receiving lengthy information requests much earlier in the audit process, in some cases even before the initial desk audit submission has been received. These requests seek documentation and evidence of the contractors’ compliance with all of the regulations that OFCCP enforces, including in particular the regulations dealing with outreach to individuals with disabilities and veterans, and a few questions pertaining to compliance with OFCCP’s regulations addressing sex discrimination (Part 60-20), and religion/national origin discrimination (Part 60-50).
The webinar will be conducted on Tuesday, May 17, 2011 from 2:00 - 3:30 PM EDT. Registration for this information session is required, and can be made here.
Photo credit: doram