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ARTICLE · 23 MARCH 2011

Labor & Employment Alert: OFCCP Issues Active Case Enforcement Directive

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Recently, the Department of Labor's Office of Federal Contract Compliance Programs ("OFCCP") issued Directive 295 (OFCCP Order No. 295 ADM Notice/Other (Dec. 16, 2010)), which sets out new procedures for conducting compliance reviews of supply and service federal government contractors.

United StatesEmployment and HR
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Alison Marshall
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Mark Temple
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Terri Chase
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Eric Dreiband
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Brian Jorgensen
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OFCCP Mandates Full Desk Audits In Every Compliance Evaluation

Recently, the Department of Labor's Office of Federal Contract Compliance Programs ("OFCCP") issued Directive 295 (OFCCP Order No. 295 ADM Notice/Other (Dec. 16, 2010)), which sets out new procedures for conducting compliance reviews of supply and service federal government contractors. The new procedures are known as Active Case Enforcement ("ACE"). ACE applies only to supply and service contractors, not construction contractors.

The directive replaces a 2003 directive that processed compliance evaluations under an Active Case Management procedure. The OFCCP's stated reason for rescinding the prior process is that "it did not allow OFCCP to effectively use all of its investigative tools." OFCCP Order No. 295, at 1

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