Another Financial Violation That Could Have Been Avoided

I always stress UNIFORMITY AND CONSISTENCY with policies and procedures. I am not an alarmist, I know how the US DOL OFCCP works.  The beauty of working with a former Compliance Officers/Investigators is our years of knowing what can cause issues.  See below: On April 30, 2015, Comcast entered into a Conciliation Agreement with OFCCP to address the notice of violation issued on March 22, 2011.  OFCCP determined that between March 2006 and September 2007 that Comcast in Everett, Washin...
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How to Stay OFCCP Compliant in Your Promotion Policy and Hiring Procedure

  To stay OFCCP compliant, be very precise in outlining your company’s Promotion Policy and Hiring Procedure.  A case was handed over to me to investigate when it was stalled by the original Compliance Officer. An Impact Ratio Analysis could not be conducted.  The original CO saw that females were not upper level Job Groups.  The assumption was potential discrimination for females. The company did not have a set procedure to handle promotions.  When a position is posted internally...
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News Release – US Labor Department secures nearly $2M in back wages, benefits for nearly 150 workers at federally-funded solar energy project in Nevada

News Release   US Labor Department secures nearly $2M in back wages, benefits for nearly 150 workers at federally-funded solar energy project in Nevada LAS VEGAS — The U.S. Department of Labor has recovered $1,914,681.50 in back wages and fringe benefits for 147 workers at Proimtu Mmi-Nv LLC, a Henderson-based subcontractor providing construction services at the federally funded Crescent Dunes Solar Energy Project in Tonopah. This project, which received a $737 million loan guarante...
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OFCCP Revised Scheduling Letter and Itemized Listing Approved by OMB

On September 30, 2014, the Office of Management and Budget (OMB) approved OFCCP’s revised scheduling letter and itemized listing.  The approval expires on March 31, 2016. As a result, OFCCP is no longer using the previous versions of these documents to schedule compliance evaluations. OFCCP will not schedule supply and service compliance evaluations from October 1 through October 15, 2014. Contractors should use this period to review and become acquainted with the new letter and itemized ...
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5 Tips on Creating a Legally Sound HR Policy

Human Resources policies and procedures establish a framework and set standards that guide how each employee should conduct themselves. This includes how a job is performed, how employees make decisions, interact with one another and manage the business operations of your company. A well-written policy leaves nothing to the imagination and lets both the employee and employer know where they stand within the company. These policies are organized, consistent and legally sound.  HR staff member...
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Hiring Procedures: 7 Tips That Will Help Your Organization Ensure Affirmative Action Compliance

For most companies, hiring procedures cause issues, not only big ones with the US DOL, but also internal problems. First, most financial violations that the US Department of Labor Office of Federal Contract Compliance Programs (OFCCP) finds are in hiring. How does a company avoid these problems? The best way is training and checks to ensure everyone knows to be consistent with policies and procedures. But let’s back up a bit. Make sure that your company Policies and Procedures are updated, and...
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