Cara Yates Crotty

Cara Yates Crotty

Constangy, Brooks, Smith & Prophete, LLP

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Final Rule and Guidance on Fair Pay & Safe Workplaces Released

Today the Federal Acquisition Regulatory Council published its Final Rule and the U.S. Department of Labor issued its Final Guidance to implement President Obama’s Fair Pay and Safe Workplaces Executive Order. The new...more

8/26/2016 - Disclosure Requirements DOL Fair Pay and Safe Workplaces Federal Acquisition Regulations (FAR) Subcontractors

Is The OFCCP’s Take On The Internet Applicant Rule Outdated?

A recent Q & A from the “Workologist” column in the New York Times caught my eye. The correspondent was asking how to ensure that a résumé submitted online actually gets reviewed by the hiring company. That is a...more

7/21/2016 - Federal Contractors Hiring & Firing Job Applicants OFCCP

Labor Complaints To Be Reported To Federal Database Of “Bad” Employers

To assist federal contractors in their compliance with the Fair Pay and Safe Workplaces Executive Order – which to date still has no final implementing regulations – the National Labor Relations Board has graciously offered...more

7/7/2016 - Executive Orders Fair Pay and Safe Workplaces Federal Contractors Labor Law Violations NLRB

Norfolk Southern Unit Agrees To Pay OFCCP $492K For Alleged Race Bias In Hiring

Do you need a reason to monitor your hiring and keep good records? Here’s one. Alleging race discrimination in the hiring process, the Office of Federal Contract Compliance Programs has settled with a unit of Norfolk...more

7/7/2016 - Federal Contractors Hiring & Firing OFCCP Race Discrimination Recordkeeping Requirements

OFCCP Issues Final Rule on Sex Discrimination

Last week, the Office of Federal Contract Compliance Programs issued its Final Rule on Discrimination on the Basis of Sex. The new regulations rescind the OFCCP’s prior Sex Discrimination Guidelines and give regulatory effect...more

6/22/2016 - EEOC Federal Contractors Gender Identity Gender-Based Pay Discrimination Hostile Environment OFCCP Pregnancy Discrimination Reasonable Accommodation Sex Discrimination Title VII

Reminder: OFCCP Pay Transparency Rule Takes Effect Monday!

The OFCCP’s Final Rule prohibiting federal contractors from discriminating against employees and applicants who ask about or discuss compensation goes into effect this Monday, January 11...more

1/8/2016 - Employee Handbooks Employment Discrimination Federal Contractors OFCCP Pay Transparency

Minimum Wage for Federal Contractors set to Increase

President Obama's Executive Order requiring certain federal contractors and subcontractors to pay an increased hourly minimum wage includes a mandate that the Secretary of Labor determine increases to the wage rate on an...more

9/22/2015 - Barack Obama DOL Executive Orders Federal Contractors Minimum Wage Subcontractors Wage and Hour

OFCCP Issues Regulations on "Pay Transparency"

Today the U.S. Office of Federal Contract Compliance Programs issued its Final Rule implementing Executive Order 13665, which prohibits federal contractors from discriminating against employees and applicants who ask about or...more

9/14/2015 - Affirmative Action Compensation & Benefits Defense Strategies Discrimination EEO Employer Liability Issues Essential Functions Executive Orders Federal Contractors Final Rules OFCCP Protected Activity Retaliation Subcontractors Transparency

Obama Orders Paid Sick Leave for Employees of Some Federal Contractors

On Labor Day, President Obama signed another Executive Order aimed at federal contractors. This time, certain federal contractors will be required to provide up to seven days of paid sick leave annually to their employees....more

9/10/2015 - Barack Obama Corporate Counsel DOL Executive Orders Federal Contractors Paid Leave Sick Leave Wage and Hour

Affirmative Action Alert: Agencies issue proposals on "Fair Pay & Safe Workplaces" Executive Order

The Federal Acquisition Regulatory Council and the U.S. Department of Labor issued simultaneous proposals to implement President Obama’s Fair Pay and Safe Workplaces Executive Order. The Executive Order, signed last July,...more

6/3/2015 - Administrative Merits Determinations Affirmative Action Arbitration Arbitration Awards DOL EEOC Enforcement Actions Executive Orders Fair Pay and Safe Workplaces Federal Acquisition Regulations (FAR) Federal Contractors OFCCP Popular Public Disclosure Subcontractors Suspensions & Debarments VEVRAA

VEVRAA hiring benchmark drops again

As announced by the Office of Federal Contract Compliance Programs, the updated national percentage of veterans in the workforce is continuing to decline, now at 7 percent....more

4/23/2015 - Benchmarks Federal Contractors Hiring & Firing OFCCP VEVRAA

OFCCP Proposes Updated Sex Discrimination Rules

The Office of Federal Contract Compliance Programs announced a proposed rule to update the agency's sex discrimination regulations. The OFCCP's existing guidelines on sex discrimination were issued in 1970 and, admittedly, do...more

1/30/2015 - Discrimination EEOC Gender Discrimination Guidance Update OFCCP Pregnancy Discrimination Sex Discrimination Title VII

OFCCP Releases Final Rule on LGBT Non-Discrimination

The Office of Federal Contract Compliance Programs announced yesterday that it is issuing a Final Rule implementing President Obama's Executive Order that prohibits federal contractors from discriminating on the bases of...more

12/5/2014 - Barack Obama Discrimination Executive Orders Federal Contractors Final Rules Gender Identity OFCCP Sexual Orientation Discrimination Subcontractors

Happy Turkey Day from the OFCCP! (not)

Once again, the Office of Federal Contract Compliance Programs will ruin the holidays for thousands of federal contractors. The OFCCP announced last week that it plans to issue Courtesy Scheduling Announcement Letters, or...more

11/18/2014 - Federal Contractors OFCCP Scheduling Letters

OMB Finally Approves New Scheduling Letter And Itemized Listing

Three years after submitting its proposed revisions to the Office of Management and Budget, the Office of Federal Contract Compliance Programs announced yesterday that it has finally received approval for its revised...more

10/2/2014 - Audits Federal Contractors OFCCP OMB Reporting Requirements Scheduling Letters

OFCCP Announces Another Proposed Rule: No More Pay Secrecy!

The Office of Federal Contract Compliance Programs announced that it will publish its Notice of Proposed Rulemaking on "pay transparency" in tomorrow's Federal Register and provided a link to the pre-publication version on...more

9/17/2014 - Barack Obama Employer Liability Issues Executive Orders Federal Contractors OFCCP Rulemaking Process Subcontractors Transparency Wages

OFCCP Proposes "Equal Pay Report" for Contractors to go with EEO-1

The Office of Federal Contract Compliance Programs issued a Notice of Proposed Rulemaking on Friday in response to President Obama's April directive that the agency develop a tool for compensation data collection. The OFCCP...more

8/12/2014 - Barack Obama EEO-1 Employer Liability Issues Equal Pay Report Federal Contractors OFCCP Rulemaking Process Subcontractors

Affirmative Action Alert Oh, No! Another Executive Order For Federal Contractors

For the fifth time in seven months, President Obama has signed an Executive Order directed solely toward federal contractors and their employees. Yesterday, he signed the "Fair Play and Safe Workplaces" Executive Order to...more

8/4/2014 - Affirmative Action Compliance Discrimination DOL Executive Orders Federal Contractors Safety Precautions

OFCCP Updates Process For Approval Of Functional AAPs, And It's Less Burdensome For Contractors

The Office of Federal Contract Compliance Programs has quietly released an updated Directive of its approval process for developing Functional Affirmative Action Plans. Although the changes are not major, the good news is...more

1/4/2013 - Affirmative Action OFCCP

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