For the first time in more than a decade, the Labor Department's Office of Federal Contract Compliance Programs (OFCCP) has issued a comprehensive update of the Federal Contract Compliance Manual (FCCM). The purpose of the manual is to provide internal guidance to help Labor Department compliance officers evaluate federal contractors' adherence to their affirmative action and equal opportunity obligations and investigate discrimination complaints. However, contractors might also be interested in taking a look at this 500-page, multichapter document.
The FCCM addresses desk audits and onsite reviews of supply and service contractors and evaluations of construction contractors. It also discusses corporate management compliance evaluations as well as functional affirmative action compliance evaluations. The manual also contains chapters dealing with complaint investigations, employment discrimination remedies, and resolutions for contractor noncompliance with requirements under Executive Order 11,246, Section 503 of the Rehabilitation Act, and Section 4212 of the Vietnam Era Veterans' Readjustment Assistance Act. (DoL recently updated these two laws with final rules that require contractors to set hiring goals for veterans and disabled people
The updated manual does not establish any new policies. As the introduction states,“The FCCM does not create new legal rights or requirements or change current legal rights or requirements for federal contractors.” However, it does spell out how compliance officers may request additional employment data from contractors for further analysis during a desk audit, and that is a new emphasis.
The revised manual is available as a downloadable PDF on OFCCP’s website.