OFCCP Game-Changing Final Rules: Complying Amid Vigorous Enforcement

Establishing Hiring Benchmarks, Meeting New Data Collection Requirements and Accommodation Rules

Recording of a 90-minute CLE webinar with Q&A

Conducted on Wednesday, April 9, 2014

Recorded event now available

or call 1-800-926-7926
Course Materials

This CLE course will provide employment counsel with the information necessary to implement policies and procedures in compliance with new rules regarding protected veterans and individuals with disabilities. The panel will review changes to the Federal Contractor Compliance Manual and how counsel can prepare employers to survive an audit.


In recent months, the Office of Federal Contract Compliance Programs (OFCCP) made significant changes to affirmative action compliance guidelines in employment practices for federal contractors. The agency substantially overhauled the Federal Contractor Compliance Manual (FCCM). Highlighted changes include making desk audits more burdensome on contractor/employers, encouraging onsite reviews, and outlining remedies for identified discrimination.

OFCCP also issued game-changing and long-anticipated final rules concerning veterans and individuals with disabilities. The changes update and strengthen federal contractors’ affirmative action and nondiscrimination responsibilities in employment. The OFCCP vowed to audit and vigorously investigate employer practices regarding compensation, hiring, promotion and termination.

Specifically, counsel must quickly grasp and help employers understand and implement new hiring benchmarks, work utilization goals, data collection and record-keeping requirements, and accountability and reasonable accommodation rules that apply to this new group of protected employees.

Listen as our distinguished panel reviews the complex, new regulations and audit approaches. The panel will provide guidance on what to expect in and how to survive the new OFCCP audits.



  1. Introduction of 503/VEVRAA regulations
  2. Posting/notice obligations
  3. Outreach and recruitment obligations
  4. Self-identification issues
  5. Data collection and analysis
  6. Reasonable accommodation issues
  7. Benchmark and utilization goals
  8. AAP requirements and preparation
  9. Impact of FCCM and audit trends


The panel will review these and other key questions:

  • What are the key and most complex requirements for protected veterans and individuals with disabilities?
  • How do the reasonable accommodation requirements now apply to protected veterans and IWDs?
  • What practices and policies should employers implement now in preparation for an audit in this new compliance environment?
  • What are the important changes in the FCCM that employers need to know now?

Following the speaker presentations, you'll have an opportunity to get answers to your specific questions during the interactive Q&A.


Connie N. Bertram
Connie N. Bertram

Proskauer Rose

Ms. Bertram advises federal government contractors and sub-contractors on the many unique employment, affirmative...  |  Read More

Jon A. Geier
Jon A. Geier

Paul Hastings

Mr. Geier represents employers in all aspects of labor and employment law. He advises federal contractors on their...  |  Read More

T. Scott Kelly
T. Scott Kelly

Ogletree Deakins Nash Smoak & Stewart

Mr. Kelly devotes the majority of his practice to representing federal contractors and sub-contractors in compliance...  |  Read More

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