Insights and Analysis

Responding to OFCCP’s new initiatives on pay equity, compliance certification, audits, and more

20 May 2022

The Hogan Lovells Employment and Government Contracts teams recently hosted a webinar discussing significant developments for federal supply and service contractors, including from the Department of Labor's Office of Federal Contract Compliance Programs (OFCCP).

This webinar is now available to view on-demand, and the presentation materials are available by clicking here.

Here are six key steps contractors can take right now to be prepared:

Complete your Affirmative Action Programs (AAPs) and certify on the AAP portal by no later than June 30, 2022. If you haven’t started, get started now!
Get prepared in advance of an OFCCP audit. Audits will have tighter deadlines and may be both more intrusive and less transparent.
Prepare a simplistic non-privileged “pay equity audit” to protect privilege on your more sophisticated pay equity audit.
If applicable, adjust pay to reflect the contractor minimum wage hike, but also track litigation developments.
Track litigation developments regarding the contractor vaccine mandate.
Implement “ban the box” in your hiring practices.

We hope you find this information insightful. If you have questions about any of the covered topics, please don't hesitate to contact one of the authors of this post or the Hogan Lovells lawyer with whom you are in regular contact.

Watch the webinar recording here.

Authored by George W. Ingham, Stacy Hadeka, Amy Folsom Kett, and Heather McAdams.