Wednesday, January 18, 2012

What Will Your Comment Be?

As promised during Director Patricia Shiu's ILG keynote speech delivered on July 27, the "game-changer" revisions to Section 503 of the Rehabilitation Act of 1973 were published for public comment on December 9, 2011.

Comments are due on 2/7/2012

Included in the comments to date is a letter from SHRM (Society for Human Resource Management) Director of Government Affairs and Chief Government Relations Officer for CUPA (The College and University Professional Association for Human Resources) requesting an extension of the comment period. This request is made due to the significance, clearly recognized by the OFCCP, of the proposed rulemaking. The letter estimates a cost impact of $81 million dollars annually to Federal contractors if the rulemaking is implemented as proposed. Additionally the letter points out that the proposal was issued during some of the busiest months of the year for HR professionals.

As stated in a recent article by Ms. Sandra Scott Ziegler, Esq., recently retired OFCCP Midwest Region Director, comments are critical on the proposed rulemaking for a number of reasons, which include:
  • OFCCP is not the only potential audience - 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.
  • Comments become a part of the rulemaking record and may be important if the legality of the rule is challenged.


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

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