Establishing Paid Sick Leave for Federal Contractors

A Proposed Rule by the Labor Department on 3/14/2016

Published in the Federal Register on 3/14/2016, this document extends the period for filing written comments until April 12, 2016 on the proposed rulemaking:  Establishing Paid Sick Leave for Federal Contractors. The Notice of Proposed Rulemaking (NPRM) was published in the Federal Register on February 25, 2016. The Department of Labor (Department) is taking this action in order to provide interested parties additional time to submit comments.

A Proposed Rule by the Labor Department on 2/25/2016

This rule proposes regulations to implement Executive Order 13706, Establishing Paid Sick Leave for Federal Contractors, signed by President Barack Obama on September 7, 2015, which requires certain parties that contract with the Federal Government to provide their employees with up to 7 days of paid sick leave annually, including paid leave allowing for family care. Executive Order 13706 explains that providing access to paid sick leave will improve the health and performance of employees of Federal contractors and bring their benefits packages in line with model employers, ensuring that Federal contractors remain competitive employers and generating savings and quality improvements that will lead to improved economy and efficiency in Government procurement.

The Executive Order directs the Secretary of Labor to issue regulations by September 30, 2016, to implement the Order's requirements. This proposed rule therefore defines terms used in the regulatory text, describes the categories of contracts and employees the Order covers and excludes from coverage, sets forth requirements and restrictions governing the accrual and use of paid sick leave, and prohibits interference with or discrimination for the exercise of rights under the Executive Order. It also describes the obligations of contracting agencies, the Department of Labor, and contractors under the Executive Order, and it establishes the standards and procedures for complaints, investigations, remedies, and administrative enforcement proceedings related to alleged violations of the Order. As required by the Order and to the extent practicable, the proposed rule incorporates existing definitions, procedures, remedies, and enforcement processes under the Fair Labor Standards Act, the Service Contract Act, the Davis-Bacon Act, the Family and Medical Leave Act, the Violence Against Women Act, and Executive Order 13658, Establishing a Minimum Wage for Contractors.

The comment period for the proposed rule ends on 3/28/2016.

View the article... 

EEOC Sends Notice of Proposed Rulemaking on ADA and Wellness Programs to OMB for Clearance

The U.S. Equal Employment Opportunity Commission (EEOC) on March 20 voted to send a Notice of Proposed Rulemaking (NPRM) on the interplay of the Americans with Disabilities Act (ADA) and the Affordable Care Act (ACA) with respect to wellness programs to the White House Office of Management and Budget (OMB) for clearance.

This proposed rule, which was approved by a bipartisan vote, would amend the regulations implementing the equal employment provisions of the ADA to address the interaction between Title I of the ADA and financial incentives as part of wellness programs offered through group health plans.

The submission of the NPRM to OMB represents the start of the regulatory process. After OMB approval, the proposed rule will be published in the Federal Register for a 60-day public notice and comment period. The NPRM cannot be made public prior to its publication in the Federal Register.

Source: EEOC

This information is intended to be educational and should not be considered legal advice on any specific matter.

More time to comment on proposed rule to collect summary pay data from federal contractors

US Labor Department will extend Equal Pay Report comment period through Jan. 5, 2015

The U.S. Department of Labor has announced a 60-day extension of the comment period for its proposed rule requiring federal contractors and subcontractors to submit an annual Equal Pay Report on employee compensation to the Office of Federal Contract Compliance Programs. Under the terms of the proposal, this requirement would apply to companies that file EEO-1 reports, have more than 100 employees, and hold federal contracts or subcontracts worth $50,000 or more for at least 30 days. Through the Equal Pay Report, OFCCP would be able to collect summary employee pay and demographic data using existing government reporting frameworks.

President Obama signed a presidential memorandum on April 8 instructing the secretary of labor to propose a rule to collect summary compensation data from federal contractors and subcontractors. The department published a notice of proposed rulemaking in the Federal Register on Aug. 8, with a deadline to submit comments by Nov. 6. The comment period will be extended through Monday, Jan. 5, 2015. To read and comment on the proposed rule, please visit http://www.dol.gov/ofccp/EPR.

OFCCP enforces Executive Order 11246, Section 503 of the Rehabilitation Act of 1973 and the Vietnam Era Veterans' Readjustment Assistance Act of 1974. These three laws require contractors and subcontractors that do business with the federal government to follow the fair and reasonable standard that they not discriminate in employment on the basis of sex, race, color, religion, national origin, disability or status as a protected veteran. 

Source: OFCCP

This information is intended to be educational and should not be considered legal advice on any specific matter.

Proposed Rule to improve pay transparency for employees of federal contractors

Prohibits federal contractors, subcontractors from discriminating against workers who discuss pay

 

The U.S. Department of Labor's Office of Federal Contract Compliance Programs today announced a proposed rule that would prohibit federal contractors from maintaining pay secrecy policies. Under the terms of the proposal, federal contractors and subcontractors may not fire or otherwise discriminate against any employee or applicant for discussing, disclosing or inquiring about their compensation or that of another employee or applicant.

"Workers cannot solve a problem unless they are able to identify it. And they cannot identify it if they aren't free to talk about it without fear of reprisal," said OFCCP Director Patricia A. Shiu. "Pay transparency isn't just good for workers. It's good for business. Fairness and openness are great qualities for a company's brand."

President Obama signed Executive Order 13665 on April 8, instructing the secretary of labor to propose a rule within 160 days to require pay transparency among federal contractors. The proposed rule, available for public inspection today, would amend the equal opportunity clauses in Executive Order 11246 to afford protections to workers who talk about pay. It would also add definitions for compensation, compensation information, and essential job functions, terms which appear in the revised clauses. The proposal also establishes two types of defenses that contractors can use against allegations of discrimination under EO 13665.

The rule will be published in the Sept. 17 issue of the Federal Register and open for public comment for 90 days. To learn more about the proposed rule, please visit http://www.dol.gov/ofccp/PayTransparencyNPRM.

Source: DOL

This information is intended to be educational and should not be considered legal advice on any specific matter.

Notice of Proposed Rulemaking to Revise the Definition of "Spouse" Under the FMLA

U.S. Secretary of Labor Thomas E. Perez announced today a proposed rule extending the protections of the Family and Medical Leave Act to all eligible employees in legal same-sex marriages regardless of where they live. The proposal would help ensure that all families will have the flexibility to deal with serious medical and family situations without fearing the threat of job loss. Secretary Perez is proposing this rule in light of the Supreme Court's decision in United States v. Windsor, in which the court struck down the Defense of Marriage Act provision that interpreted "marriage" and "spouse" to be limited to opposite-sex marriage for the purposes of federal law.

The FMLA, enacted in 1993, entitles eligible employees of covered employers to take unpaid, job-protected leave for specified family and medical reasons. Employees are, for example, entitled to take FMLA leave to care for a spouse who has a serious health condition. Millions of workers and their families have benefited since the FMLA's provisions became effective and even more American families would be made secure as a result of the proposed rule. 
 
"The basic promise of the FMLA is that no one should have to choose between succeeding at work and being a loving family caregiver," said Secretary Perez. "Under the proposed revisions, the FMLA will be applied to all families equally, enabling individuals in same-sex marriages to fully exercise their rights and fulfill their responsibilities to their families."

The proposed rule would change the FMLA regulatory definition of "spouse" so that an eligible employee in a legal same-sex marriage will be able to take FMLA leave for his or her spouse or family member regardless of the state in which the employee resides. Currently, the regulatory definition of "spouse" only applies to same-sex spouses who reside in a state that recognizes same-sex marriage. Under the proposed rule, eligibility for FMLA protections would be based on the law of the place where the marriage was entered into, allowing all legally married couples, whether opposite-sex or same-sex, to have consistent federal family leave rights regardless whether the state in which they currently reside recognizes such marriages.

Following the Windsor decision, noting that it was "a victory... for families that, at long last, will get the respect and protection they deserve," President Obama directed the Attorney General to work with the Cabinet to review federal statutes to ensure the decision, including its implications for federal benefits and obligations, is implemented.

For additional information on the FMLA, including information and fact sheets on the proposed revisions, visit http://www.dol.gov/whd/fmla/nprm-spouse. The department encourages all interested parties to view the proposed rule and submit comments at http://www.regulations.gov. The regulation identification number is 1235-AA09. Comments must be received within 45 days following publication in the Federal Register.

Source: DOL

This information is intended to be educational and should not be considered legal advice on any specific matter.

OFCCP Announces 2013 Agenda

On December 21, 2012, the Office of Federal Contracts Compliance Programs ("OFCCP") published its 2013 regulatory goals in the Unified Agenda of Regulatory and Deregulatory Actions ("Unified Agenda"), as required by Executive Order. The Unified Agenda signals that OFCCP intends to aggressively implement new rules and regulations affecting federal contractors and subcontractors in the upcoming year. These rules and regulations are expected to comport with OFCCP's goals as outlined in its Fiscal Year 2013 Congressional Budget Justification and its Notices of Proposed Rulemaking ("NPRM") for veterans and individuals with disabilities, which were issued in April and December of 2011, respectively. For more information regarding Section 503 of the NPRM, see our client alert of January 18, 2012 OFCCP Notice of Proposed Rulemaking.

Contractors and Subcontractors should expect OFCCP regulatory action to include the following:

1. Implementation of final rules for individuals with disabilities and covered veterans, including:
   1. Increased enforcement with respect to hiring, worker retention and data collection
   2. Increased desk audits, on-site activity, and increased focus on Section 503 and VEVRAA
2. Implementation of new pay equity data collection tools
3. Focus on the construction industry
4. Implementation of "Good Jobs for Everyone"
   1. OFCCP will place greater emphasis on "meaningful and effective" affirmative action evaluations
5. New Functional Affirmative Action Program ("FAAP") directive
   1. Permits contractors to develop Affirmative Action Plans ("AAP") based on business function or business unit rather than contractor establishments
   2. Contractors are not eligible for FAAP renewal unless two functional units have passed compliance evaluations during the agreement's three-year term
6. Executive Order 13495—Nondisplacement of Qualified Workers Under Service Contracts
   1. New requirement to offer jobs to predecessor contractor's workers
   2. Effective January 18, 2013

I. Final Rules and Regulations for Veterans and Individuals with Disabilities

OFCCP plans to finalize regulations concerning protected veterans and individuals with disabilities in April of 2013.

Veterans

Final VEVRAA regulations are scheduled for release in April of this year. The regulations are expected to require that "contractors and subcontractors conduct more substantive analyses of recruitment and placement actions taken under VEVRAA and . . . require the use of benchmarks to measure the effectiveness of affirmative action efforts. The rule would also make revisions to recordkeeping requirements."

A copy of the Notice of Proposed Rulemaking can be found here.

OFCCP will require contractors to list job vacancies and contact information for each of their locations with appropriate employment delivery systems, engage in at least three specified types of outreach and recruitment efforts each year, provide applicants with a pre-offer invitation to self-identify as "protected veterans," and increase data collection requirements for job referrals, applicants and hires.

Individuals with Disabilities

Final Section 503 rules are expected to require that contractors annually review recruitment effort effectiveness, enter into at least three linkage agreements, and provide employees with invitations to self-identify as persons with disabilities. The new rules will also broaden the definition of "disability," include new job posting requirements, establish a 7% National Utilization Goal, impose written reasonable accommodation procedures, increase data collection requirements, and revise compliance procedures.

A copy of the Notice of Proposed Rulemaking can be found here.

These new VEVRAA and Section 503 regulations will impose substantial administrative burdens on contractors and warrant in-depth review of current AAPs and employment policies to ensure compliance.

II. Pay Equity

Increased Data Collection

Pay equity featured prominently in the 2012 presidential election, and that issue promises to remain an Obama administration priority. In conformity with this objective, OFCCP plans to develop a compensation data collection tool to analyze pay disparities. This policy, however, has drawn harsh criticism. The EEOC commissioned the NAS, at the request of the White House, to review proposed methods for measuring and collecting compensation data. Their report concluded, in part, that OFCCP should not move forward with the increased data collection requirements because OFCCP failed to adequately articulate its vision of how the agency would utilize collected wage data or to measure the benefits of increased data collection against the burdens and costs to contractors.
Despite NAS recommendations, OFCCP listed June 2013 as its target date to issue a NPRM concerning the data collection tool. OFCCP has not indicated whether or how the agency plans to address any of the NAS concerns during the interim, but contractors should prepare for increased data collection obligations.

III. Focus on the Construction Industry

OFCCP intends to issue a NPRM with revised regulations governing federal and federally assisted construction contractors and subcontractors by October of 2013. Proposed rules would update "timetables for the utilization of minorities and women based on appropriate workforce, demographic or other relevant data." In addition, proposed rules would require "strengthen[ed] affirmative action programs particularly in the areas of recruitment, training, and apprenticeships."

Amendments to the Sex Discrimination Guidelines

According to the Department of Labor's Fall 2012 Statement of Regulatory Priorities, "Sex Discrimination Guidelines, found at 41 CFR Part 60-20, have not been updated in more than 30 years[.]" OFCCP intends to issue a NPRM in August of 2013 setting forth contractors' obligations not to discriminate on the basis of sex under Executive Order 11246 . . . and Title VII of the Civil Rights Act of 1964," as amended. Construction contractors should note that OFCCP has specifically stated that "[t]he nondiscrimination requirement of Sex Discrimination Guidelines . . . applies to contractors and subcontractors performing under federally assisted construction contracts." With sex discrimination in the construction industry soon to become an OFCCP priority, construction contractors should prepare for additional scrutiny.

IV. "Good Jobs for Everyone"

In its FY 2013 Budget Justification, OFCCP noted that "the agency's enforcement activities focused primarily on hiring discrimination." The agency now plans to "plac[e] greater emphasis on meaningful and effective affirmative action evaluations." In addition, OFCCP will "step[] up its enforcement of equal employment opportunity for individuals with disabilities and covered veterans with respect to hiring, worker retention, and data collection." Contractors should anticipate increased enforcement activities in all aspects of affirmative action.

V. New Functional Affirmative Action Program ("FAAP") Directive

OFCCP recently implemented Directive No. 305, effective December 17, 2012 through December 31, 2015. Directive 305 lifts a moratorium on the issuance and renewal of FAAP agreements that had been in effect since February of 2010. FAAP agreements permit contractors to develop affirmative action plans based on business function or business unit rather than contractor establishment. But despite the potential benefits of establishing affirmative action plans based on business function or unit, contractors are not eligible for FAAP renewal unless two business functions or units have passed compliance evaluations during the agreement's three-year term. Contractors should consult an attorney before determining whether a FAAP or traditional establishment-based Affirmative Action Plan is more appropriate for their businesses.

VI. Executive Order 13495—Nondisplacement of Qualified Workers Under Service Contracts

On January 30, 2009, President Obama signed Executive Order 13495, which requires federal contractors and subcontractors that enter into contracts that succeed contracts for performance of the same or similar services at the same location to offer non-managerial and non-supervisory employees who were employed under the predecessor contractor a right of first refusal of employment. According to Department of Labor Regulations, the succeeding employers are not permitted to deny employment to such predecessor employees without "written credible information provided by a knowledgeable source" such as "department or agency officials responsible for monitoring performance under the contract." The EO is effective as of January 18, 2013, when both the United States Department of Labor and Federal Acquisition Regulatory Council final rules went into effect.

Source: Lexology

This information is intended to be educational and should not be considered legal advice on any specific matter.

H2H - Hero 2 Hired

One of the contractor requirements of proposed Veteran regulations is to establish linkages agreements with specific sources (employment delivery systems) for recruiting and outreach.  A specifically named source is: "One or more of the veterans' service organizations listed on the National Resource Directory". 

H2h - Hero 2 Hired is such an organization.  In addition to the benefits of outreach and recruiting with this site, employers can access detailed information about tax credits and other incentives available, including forms and contact information.

Click here to visit H2H - Hero to Hired

Click here to vist our Veteran Resource page for other helpful Veteran links

THOMAS HOUSTON associates, inc. can assist you in meeting the challenges that will arise as a result of the upcoming OFCCP's regulatory efforts. We offer pro-active and proven compliance tools and methods.  For more information on the services offered by THOMAS HOUSTON associates, inc., call (800) 330-9000 or click here to schedule a convenient time to receive a call from a member of our Sales Team.

This information is intended to be educational and should not be considered legal advice on any specific matter.

Comments Count - Congress is Paying Attention

On February 6th, the Department of Labor announced a 14-day extension of the comment period for its proposed rule to revise regulations implementing Section 503 of the Rehabilitation Act of 1973, which obligates most federal contractors and subcontractors to ensure equal employment opportunity for qualified workers with disabilities.

Although previous extension requests had been rejected, this announcement comes after a January 17 letter from Congress asking the OFCCP to extend the comment period on the NPRM.  Additionally the letter questions the legal authority under 503 for the OFCCP to establish a numerical hiring standard, raising concern about instituting a quota.  Other concerns raised include the conflict of the pre-offer request to self-identify with the statutory language of the Americans with Disabilities Act (ADA) and the potential paperwork and recordkeeping burdens to employers.

It would appear that Ms. Sandra Scott Ziegler, Esq., recently retired OFCCP Midwest Region Director,  was accurate in her January 7 2012 article: "Commenting on the Section 503 Notice of Proposed Rulemaking: What You Need to Know" when explaining why comments on proposed rulemaking are  crtical.  Ms Ziegler points out that the OFCCP is not the only potential audience for comments.  The OMB (Office of Management and Budget) as well as elected officials may be influenced by the comments and by how much interest the rule has generated as measured by the volume of comments received.

Click here to read the letter from Congress to the OFCCP
Click here to read Ms. Zieger's article
Click here to read Highlights of the NPRM

THOMAS HOUSTON associates, inc. can assist you in meeting the challenges that will arise as a result of the upcoming OFCCP's regulatory efforts. We offer pro-active and proven compliance tools and methods.

For more information on the affirmative action compliance services offered by THOMAS HOUSTON associates, inc. visit www.thomashouston.com, call (800) 330-9000 or click here to schedule a convenient time for a call from an Affirmative Action Consultant.

Section 503 NPRM Comment Period Extended

From the OFCCP:

On December 9, 2011, the Office of Federal Contract Compliance Programs (OFCCP) published in the Federal Register a notice of proposed rulemaking (NPRM). This NPRM (76 FR 77056) proposes to revise the regulations implementing the nondiscrimination and affirmative action regulations of section 503 of the Rehabilitation Act of 1973, as amended.

The original comment period is scheduled to end on Tuesday, February 7, 2012. After receiving several requests for extensions, OFCCP is extending the comment period for this NPRM for 14 days until Tuesday, February 21, 2012. This action will provide all interested persons additional time to analyze the issues and provide their comments on the NPRM. Parties who filed comments previously may supplement or submit additional comments during the extended comment period. Parties interested in commenting can view the NPRM and submit comments by using the Federal eRulemaking Portal http://www.regulations.gov/ and referencing RIN 1250-AA02.

OFCCP is publishing a Federal Register notice announcing this two-week extension of the comment period.

THOMAS HOUSTON associates, inc. can assist you in meeting the challenges that will arise as a result of the upcoming OFCCP's regulatory efforts. We offer pro-active and proven compliance tools and methods.

For more information on the affirmative action compliance services offered by THOMAS HOUSTON associates, inc. call (800) 330-9000 or click here to schedule a convenient time for a call from an Affirmative Action Consultant.

Proposed rulemaking to implement statutory amendments to Family and Medical Leave Act

The U.S. Department of Labor is issuing a notice of proposed rulemaking to implement new statutory amendments to the Family and Medical Leave Act that would expand military family leave provisions and incorporate a special eligibility provision for airline flight crew employees.

The proposed language would extend the entitlement of military caregiver leave to family members of veterans for up to five years after leaving the military. At this time, the law only covers family members of "currently serving" service members. Additionally, the proposal expands the military family leave provisions of the FMLA by extending qualifying exigency leave to employees whose family members serve in the regular armed forces. Currently, the law only covers families of National Guard members and reservists.

For airline flight crew employees, the proposed revision makes the benefits of the FMLA more accessible. It would add a special hours of service eligibility requirement for them and specific provisions for calculating the amount of FMLA leave used that better take into account the unique — and often difficult to track — hours worked by crew members.

Download the proposed rule here

Review the FAQs here

Read the DOL press release here

THOMAS HOUSTON associates, inc. can assist in meeting the challenges that will arise as a result of upcoming regulatory efforts. We offer pro-active and proven compliance tools and methods.

For more information on the compliance services offered by THOMAS HOUSTON associates, inc. visit www.thomashouston.com, call (800) 330-9000 or click here to schedule a convenient time for a call from a consultant.

Proposed Reasonable Accommodation Procedure Requirements

The Notice of Proposed Rulemaking (NPRM) to revise the regulations implementing the non-discrimination and affirmative action regulations of section 503 of the Rehabilitation Act of 1973, require the development and implementation of written procedures for processing requests for reasonable accommodation. While it is true that procedures may vary due to the size, structure, and resources of a company, there are specific elements put forth in the proposed regulations that must be included in all procedures:

1. Contact information for responsible official - This official may be the same official responsible for the implementation of the contractor's affirmative action program, and must have the authority, resources, support, and access to top management necessary to effectively implement the reasonable accommodation procedures.
2. Reasonable accommodation requests -
   • How - Clarification that reasonable accommodation requests may be made verbally or in writing, with no required verbiage, by an applicant, employee or third party;
   • When - Stipulation that a request may be made at any time and does not have to be repeatedly submitted for a recurring need (i.e. Sign Language Interpreter);
   • Who - Identification of whom a request should be submitted to: At a minimum, this should include someone in the employees chain of command AND the named official responsible for implementation, and;
   • Applicant notification - Process by which applicants will be notified of the company's reasonable accommodation obligation and the right of all applicants to request a reasonable accommodation to participate in the application process. Additionally, provisions for processing applicant requests within the application process timeframe.
3. Written Confirmation - Although a reasonable accommodation request can be made in different ways, it is required that all requests be confirmed in writing and include:
   • Date accommodation request was received (for oral requests this is the day the oral request was made); and
   • Signature by the authorized decision maker.
4. Processing Timeframes - A company may set its own timeframe for processing requests - however the proposed rule specifies a requirement of 5-10 business days without the need for supporting medical documentation and no more than 30 days where supporting medical documentation or special equipment is required. Procedures should explain any extenuating circumstances that may result in going beyond the stipulated time frames and the written notification used to advise the requestor of the delay.
5. Process Description - A description of the steps involved, specific information required, and the interactive process that may be initiated with the requestor.
6. Medical Documentation - Parameters must be defined for any required medical documentation and include the following:
   • Not open-ended;
   • Limited to the disability and functional limitations; and
   • Required only if disability and reasonable accommodation is not known or obvious.
7. Denial - Stipulation that denials must be in writing and include:
   • Reason with date and signature by the authorized decision maker;
   • Any relative information about an internal appeal process;
   • A statement advising requestor of their right to file a discrimination complaint.
8. Confidentiality - Indication that all requests for reasonable accommodation and related documentation will be treated as a confidential medical record and will be maintained in a separate medical file.

For more information on this proposed rule:

Read the complete highlight article, Fact Sheet, or Frequently Asked Questions from the OFCCP.

Click here to download the proposed rule

Click here to comment on the proposed rule

Comment period closes 2/7/2012  2/21/2012

THOMAS HOUSTON associates, inc. can assist you in meeting the challenges that will arise as a result of the upcoming OFCCP's regulatory efforts. We offer pro-active and proven compliance tools and methods.

For more information on the affirmative action compliance services offered by THOMAS HOUSTON associates, inc. visit our website www.thomashouston.com, call (800) 330-9000 or click here to schedule a convenient time for a call from an Affirmative Action Consultant.

Highlights of the Proposed Rule for Individuals with Disabilities

On December 9, 2011 the OFCCP published a Notice of Proposed Rulemaking (NPRM) to revise the regulations implementing the non-discrimination and affirmative action regulations of section 503 of the Rehabilitation Act of 1973, as amended.  The  revisions will increase Federal contractor affirmative action obligations to ensure equal employment opportunities for qualified workers with disabilities.

Highlights of the proposed rule: / comment requests include:

• Goal / Goal Range / Sub-Goal: Establish a hiring goal of 7 percent for individuals with disabilities in each job group. Also being proposed are: a utilization goal range rather than the fixed 7 percent goal, and a 2 percent sub-goal for individuals with certain particularly severe or targeted disabilities.
• Invitation to Self Identify:  a) Invite all applicants to voluntarily self-identify as an “individual with a disability” at the pre-offer stage of the hiring process; b) invite post-offer voluntary self-identification and conduct an annual survey of all employees.
• Record-Keeping: Maintain records on the number of individuals with disabilities referred to, applying for and hired to open positions for a period of 5 years.
• Accommodation Requests: Develop and implement written procedures for processing requests for reasonable accommodation.
• Outreach / Linkage Agreements: Engage in linkage agreements with a minimum of three specific types of outreach and recruitment efforts to recruit individuals with disabilities.
• Job Listings: List job openings with One-Stop Career Centers or other appropriate employment delivery systems.
• Annual Reviews: Require the previously recommended steps to review personnel processes, as well as physical and mental job qualifications.

Read the complete highlight article, Fact Sheet, or Frequently Asked Questions from the OFCCP

Click here to download the proposed rule
Click here to comment on the proposed rule. 
Comment period closes 2/7/2012  2/21/2012.

THOMAS HOUSTON associates, inc. can assist you in meeting the challenges that will arise as a result of the upcoming OFCCP's regulatory efforts. We offer pro-active and proven compliance tools and methods.

For more information on the affirmative action compliance services offered by THOMAS HOUSTON associates, inc. visit www.thomashouston.com, call (800) 330-9000 or click here to schedule a convenient time for a call from an Affirmative Action Consultant.