Presented by Epstein Becker Green attorneys:
Thomas A. Cox
Dean R. Singewald
Kristie Brooks-Smith
Peter M. Stein

With the increased enforcement measures taken in 2011 by the Office of Federal Contract Compliance Programs ("OFCCP") of the United States Department of Labor, federal government contractors and covered subcontractors subject to the affirmative action requirements of Executive Order 11246, the Rehabilitation Act and the Vietnam Era Veterans' Readjustment Assistance Act now more than ever need to ensure that their written Affirmative Action Program ("AAP") plan documents will withstand the scrutiny of an OFCCP compliance review.

Using a 360 evaluation approach, we will examine a hypothetical submission to the OFCCP in response to a compliance review that will allow you to evaluate your organization's current AAP and your ability to comply with a plethora of information and document requests by the OFCCP during such a review. The program will consist of:

  • Mock Audit: Using the OFCCP compliance review process, we will address what is involved in such an audit, and the pitfalls to be avoided. We will discuss how AAP information should be communicated to the OFCCP; what issues should be discussed and/or resolved prior to the submission; what analyses should be performed regarding progress towards placement goals, selection process outcomes, and compensation distribution; and who should be included in preparing for an OFCCP onsite visit, if scheduled.
  • AAP Evaluation: We will address the individual components of your written AAP, and the steps to be taken in its implementation. We will discuss how to strategically prepare your workforce and job group analyses; what factors to consider when identifying data for inclusion in your availability analysis; how to develop your comparison of incumbency to availability and the various methods to determine goal setting; and what needs to happen once placement goals are set. We will also discuss the importance of correctly tracking your applicants and the right way to analyze your hires, promotions and terminations data. Further, we will review the good faith steps to take to tackle underutilization, identify problem areas, create action-orientated programs, and engage in community outreach.
  • Assessment Tool: Attendees will receive an assessment tool that you will be able to use to critically evaluate your current AAP plan documents and good faith efforts, and to identify areas that need improvement.

We hope you will join us for this timely and informative briefing.

To register, please e-mail

If you have questions about this briefing, please contact
Christine Eschenauer at (212) 351-4668 or

Epstein Becker Green is an approved provider of New York Continuing  Legal Education (CLE) credit.  This seminar is approved for 2.0 hours of credit in Professional Practice, and is transitional and appropriate for both newly admitted and experienced attorneys.  Please note that in order to receive full credit for attending this briefing, the registrant must be present for the entire session. Full scholarships to attend EBG Breakfast Briefings will be granted to nonprofit organizations, public sector employees and others for whom budgeting constraints would otherwise preclude attendance. To apply, send your request, stating the reason for your interest, to Christine Eschenauer, at Epstein Becker Green is an approved service provider for New Jersey CLE.  This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 2.0 hours of total CLE credit. 

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