On September 2, 2014, the Office of Federal Contract Compliance Programs (OFCCP) published in the Federal Register a proposed renewal of the current record-keeping, notice, and reporting requirements imposed by Executive Order 11246 for federal construction contractors and subcontractors. The current requirements are set to expire on December 31, 2014.

Of interest is not necessarily the proposed renewal but OFCCP’s estimate that it would cost contractors an average of $497 per year and require a combined total of 16 hours per year to maintain compliance with these regulations. Our experience with our federal construction contractor clients reveals that these estimates are extremely low.

In the proposed renewal, OFCCP estimates that there are currently approximately 52,429 federal construction contractors. If your organization qualifies as a construction contractor, OFCCP wants to hear from you and has invited public comment until November 3, 2014, on the proposed renewal.

In other news, OFCCP is also working on revising the regulations affecting federal construction contractors and expects to publish these revised rules in January of 2015. There is wide speculation that these new rules could include an update to the female utilization goal. These regulations could be more “game-changers” for federal construction contractors like the controversial veteran and disability regulations that became effective on March 24, 2014.As a result of the agency’s continued focus on the construction industry, we recommend that federal construction contractors take steps to maintain compliance.


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The Capitol - Washington DC
Practice Group

Government Contracting and Compliance

The experienced attorneys in our Government Contracting and Compliance Practice Group advise and represent employers regarding the unique risks and compliance challenges they face when they do business with the federal government.

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