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Opinion Letter Federal Contractors

FordHarrison

DOL Relaunches Opinion Letter Program Amid Shifting Enforcement Priorities

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On June 2, 2025, the Department of Labor (DOL) launched its Opinion Letter program. Opinion Letters are official written responses from the DOL that explain how it would apply statutes and regulations under particular facts...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Trump Administration Proposes Elimination of OFCCP, Launches New Opinion Letter Program for Labor Guidance

The Trump administration plans to completely eliminate the Office of Federal Contract Compliance Programs (OFCCP) and transfer the agency’s remaining authority to enforce protections in federal contractors for veterans and...more

Womble Bond Dickinson

Handle with Care: FCPA Travel & Hospitality Expenses

Womble Bond Dickinson on

Two recent Foreign Corrupt Practices Act (FCPA) actions – a Department of Justice (DOJ) Opinion letter and an SEC settlement – underscore key diligence questions that legal and compliance departments should address when...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Beltway Buzz - January 2021 #4

Status Check on Congress. We are more than one week into the Biden administration and the president has made progress filling out his cabinet. Antony Blinken (U.S. secretary of state), Janet Yellen (U.S. secretary of the...more

Polsinelli

OFCCP Issues Opinion Letter Protecting “Controversial” Religious Beliefs

Polsinelli on

On January 8, 2021, the Office of Federal Contract Compliance Programs (OFCCP) issued an opinion letter on “Legal Protections for Religious Liberty in the Workplace.” The opinion letter builds on OFCCP’s recent regulations...more

Proskauer - Government Contractor Compliance...

OFCCP Publishes Opinion Letter on Protections for Religious Liberty in (and out of) the Workplace

On January 8, 2020, the Office of Federal Contract Compliance Programs (“OFCCP”) published an opinion letter responding to an unidentified religious organization’s request for clarification on the “scope of the legal...more

Polsinelli

OFCCP Disclaims Jurisdiction Over Participants in the Defense Department’s SkillBridge Job Training Program

Polsinelli on

On November 8, 2019, OFCCP released another opinion letter clarifying the extent of its jurisdiction over government contractors.  In the letter, OFCCP opined that participants in the Department of Defense’s SkillBridge...more

Skadden, Arps, Slate, Meagher & Flom LLP

Employment Flash - September 2019

This edition of Employment Flash looks at a series of recent NLRB decisions, many of which apply to all employers, not just those with unionized employees. We also discuss other U.S. federal and state labor and...more

Proskauer - Government Contractor Compliance...

OFCCP’s Second Opinion Letter: Contractors Can Seek Advance Approval of PAGs, But…

On July 22, 2019, OFCCP issued its second published opinion letter addressing whether “contractors can work with OFCCP to develop a PAG [Pay Analysis Grouping] structure that OFCCP would accept as valid for use in future...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

Beltway Buzz - July 2019 #3

DOL Personnel Moves. While we all wait to see how and when the confirmation process for secretary of labor nominee Eugene Scalia may play out, the front office shake-up at the U.S. Department of Labor (DOL) continued this...more

Polsinelli

OFCCP Opinion Letter Endorses Pre-Approval of PAGs

Polsinelli on

In a welcome development for federal government contractors, OFCCP issued its second opinion letter on July 22, 2019.  The opinion letter endorsed a process through which contractors can submit proposed pay analysis groups...more

Littler

OFCCP Issues Opinion Letter on Whether Pre-Approved Pay Analysis Groupings Will be Accepted in Future Audits

Littler on

On July 22, 2019, the Office of Federal Contract Compliance Programs (OFCCP) issued its second Opinion Letter since November 30, 2018, when Directive 2019-03 announced the agency’s intent to begin delivering such guidance to...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

OFCCP’s New Opinion Letter and FAQs Provide New Guidance to Contractors

In keeping with its commitment to promoting transparency, this week the Office of Federal Contract Compliance Programs (OFCCP) released an official opinion letter concerning pay analysis groupings (PAGs) and three sets of...more

Jackson Lewis P.C.

OFCCP Issues Pay Analysis Grouping Opinion Letter

Jackson Lewis P.C. on

In just its second Opinion Letter, OFCCP has [somewhat] tackled the issue of Pay Analysis Groups (PAGs). Issued two months after the inaugural Opinion Letter which addressed the issue of Pell Grants, Director Craig Leen’s...more

Constangy, Brooks, Smith & Prophete, LLP

OFCCP Issues Its First Opinion Letter

Does receiving Pell Grant funds make you a contractor? Last November, the Office of Federal Contract Compliance Programs issued a Directive announcing that it would begin issuing opinion letters to provide easily...more

Polsinelli

OFCCP Issues its First Opinion Letter Regarding Pell Grants

Polsinelli on

On May 23, 2019, the OFCCP -- without fanfare -- issued its first opinion letter since its announcement last year that it would begin issuing opinions to provide guidance to the contractor community.  ...more

Proskauer - Government Contractor Compliance...

OFCCP’s First Published Opinion Letter: Pell Grants Do Not Make Universities Federal Contractors

On May 23, 2019, OFCCP issued its first published opinion letter addressing whether universities and other post-secondary higher educational institutions become covered federal contractors by serving as a “conduit” for Pell...more

Littler

OFCCP Issues Opinion Letter on Whether Pell Grants Trigger Federal Contractor Status for Colleges

Littler on

In an effort to provide additional compliance assistance resources to contractors, the Office of Federal Contract Compliance Programs (OFCCP) issued Directive 2019-03 in late 2018. Under this Directive, OFCCP announced...more

Jackson Lewis P.C.

OFCCP Issues First Opinion Letter

Jackson Lewis P.C. on

As we noted at the beginning of the year, the Agency in late-November 2018 issued a Directive stating it would develop "a dynamic and searchable publically available source of Help Desk questions and answers to assist...more

Proskauer - Government Contractor Compliance...

OFCCP Shares Some News At Financial Industry Town Hall

On April 9, 2019, in New York City, OFCCP hosted a town hall focused on the “financial industry and related fields.” Guy Brenner of Proskauer attended what was an enlightening and informative event. The purpose of the town...more

Skadden, Arps, Slate, Meagher & Flom LLP

Employment Flash - March 2019

This edition of Employment Flash looks at developments in labor and employment law, including with respect to minimum salary thresholds for the DOL's new overtime rule, the EEOC's collection of compensation data for increased...more

Proskauer - Government Contractor Compliance...

OFCCP Invites Contractors to Submit “Burning Questions”

Quick Hit: OFCCP is inviting contractor stakeholders, and their legal counsel, to submit “Burning Question[s]” to its Help Desk that the agency can answer in forthcoming Opinion Letters. Key Takeaways: OFCCP’s invitation is...more

Jackson Lewis P.C.

OFCCP Opinion Letters – The Agency Wants To Answer Contractors’ Questions

Jackson Lewis P.C. on

As part of OFCCP’s continuing efforts at transparency, the Agency in late-November 2018 issued a Directive stating it would develop “a dynamic and searchable publically available source of Help Desk questions and answers to...more

Ogletree, Deakins, Nash, Smoak & Stewart,...

OFCCP Year in Review and What to Expect in 2019

The year 2018 brought increased activity and significant changes to the Office of Federal Contract Compliance Programs (OFCCP), including the appointment of new Director Craig E. Leen and the arrival of 12 new directives. ...more

Sheppard Mullin Richter & Hampton LLP

OFCCP Issues Contractor Friendly Directives That Aim to Streamline Investigative Processes and Decrease Contractor Guesswork

Directly in line with the U.S. Department of Labor’s Office of Federal Contract Compliance Program’s (OFCCP) new policy emphasis on agency transparency, accountability, efficiency and collaborative resolution, the OFCCP...more

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