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OFCCP Proposes Updates to Scheduling, Compliance Check, and Focused Review Letters

On April 12, 2019, the OFCCP submitted new forms of its scheduling, compliance check, and Section 503 focused review letters to the Office of Management and Budget (OMB) for approval. ...more

Polsinelli Insights from Supreme Court Oral Arguments Concerning FOIA Disclosure Obligations

On April 22, 2019, the U.S. Supreme Court heard argument in Food Marketing Institute v. Argus Leader Media. Polsinelli attended the oral arguments to provide insight concerning the potential implications for federal...more

Law Firms: Are You Ready for OFCCP to Come Knocking?

“Glaring,” “concerning,” “troubling,” “problematic,” and “systemic” were some of the words used by OFCCP Director Craig Leen to describe the underrepresentation of women, minorities, and individuals with disabilities at large...more

NLRB Judge: Requiring Confidential Arbitration is an Unfair Labor Practice

While the U.S. Supreme Court’s recent decisions have generally supported the enforceability of employment-related arbitration agreements, mandatory employment arbitration remains under fire in other contexts.  ...more

OFCCP Again Lowers VEVRAA Hiring Benchmark

On March 27, 2019, the Office of Federal Contract Compliance Programs (OFCCP) announced that it was lowering the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) hiring benchmark again this year. ...more

OFCCP Releases Corporate Scheduling Announcement List Online

On March 25, 2019, the OFCCP released its Corporate Scheduling Announcement List (CSAL) online for public access. The CSAL identifies 3,500 contractor establishments that will be audited by OFCCP, with a portion of those...more

EEOC Not Requiring Pay Data with EEO-1 Submissions for Now, But Uncertainty Remains

On March 4, 2019 Judge Chutkan of the U.S. District Court for the District of Columbia issued a ruling that immediately reinstated the EEO-1 pay data reporting requirement....more

Employers Must Prep for New EEOC Data Reporting Rule

Employers who thought that they had received a respite from the U.S. Equal Employment Opportunity Commission’s proposed requirement to report information about employees' pay and hours worked when submitting their annual...more

Ninth Circuit Narrowly Construes Scope of Protected Activity for Sarbanes-Oxley Whistleblower Claim

In Wadler v. Bio-Rad Laboratories, Inc., the U.S. Court of Appeals for the Ninth Circuit adopted a limited, plain meaning construction of the types of reports that are protected by the Sarbanes-Oxley Act’s (SOX) whistleblower...more

New FAR Provision Implements Sweeping Definition of “Recruitment Fees” in Human Trafficking Prohibition

On January 22, 2019, a new rule went into effect providing much-needed guidance on the definition of “recruitment fees” under the FAR human trafficking prohibition. ...more

OFCCP CSALs Are Just Around the Corner, Including Section 503 Focused Reviews

With the posting of 2019 CSAL notices possibly imminent, government contractors should prepare for the fact that a portion (approximately 500 out of 3,500 total) of the OFCCP’s FY 2019 compliance evaluations will be Section...more

EEOC Announces Deadlines (For Now) for Submission of 2018 EEO-1 Data

On February 1, 2019, the Equal Employment Opportunity Commission (“EEOC”) announced that it would postpone the opening of the submission period for EEO-1 survey responses until “early March 2019” and extend the deadline for...more

Employer’s Failure to Compel Arbitration Shows the Tricky Balance Employers Face when Implementing New Mandatory Arbitration...

Employers may choose to implement arbitration programs to manage the costs and risks of employment-related litigation. Arbitration may minimize negative publicity, and may further assist employers to keep costs low and reduce...more

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