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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Practice Group

OFCCP Compliance, Government Contracting, and Reporting

The experienced attorneys in our OFCCP Compliance, Government Contracting, and Reporting Practice Group advise and defend federal contractors and subcontractors on jurisdictional, compliance, and enforcement issues relevant to government contracting, including those involving the Office of Federal Contract Compliance Programs (OFCCP).

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