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ARTICLE · 11 DECEMBER 2018

New OFCCP Directive Introduces Early Resolution Procedures For Compliance Evaluations

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Quick Hit: OFCCP's new Directive 2019-02 sets forth Early Resolution Procedures ("ERP") to resolve violations discovered during a desk audit of contractors with multiple establishments.

United StatesGovernment, Public Sector
Guy Brenner
Guy Brenner
Alex Weinstein
Alex Weinstein
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Quick Hit: OFCCP's new Directive 2019-02 sets forth Early Resolution Procedures ("ERP") to resolve violations discovered during a desk audit of contractors with multiple establishments. OFCCP touts that "ERP allows OFCCP and contractors with multiple establishments to cooperatively develop corporate-wide compliance with OFCCP's requirements." Contractors who successfully resolve violations through ERP will be spared full scale compliance evaluations, but will have to agree to conciliation agreements that will include five years of monitoring and commitments to rectify similar issues at some or all of the contractor's other establishments. In return, contractors will receive a five-year moratorium on compliance evaluations of some or all of their establishments.

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