The Office of Federal Contract Compliance Programs (OFCCP) finally released the new Federal Contract Compliance Manual (FCCM) today. The new FCCM has been anticipated for several months. We understand that OFCCP trained its staff on the FCCM earlier this summer. OFCCP states that the FCCM provides “the procedural framework for executing quality and timely compliance evaluations and complaint investigations.” However, it is important to note that the FCCM does not create any new legal requirements and is not binding on federal contractors or OFCCP.
We expect that, as a result of the new manual, we will immediately see some differences in the manner in which OFCCP conducts compliance evaluations.