With the top leadership of the Biden Administration’s Office of Federal Contract Compliance Programs (OFCCP) now in place, we thought it might be helpful to do a comparison of OFCCP enforcement activity during the Trump Administration versus the Obama Administration to see if it might provide insight as to what federal contractors might expect over the next several years. This of course is premised on the assumption that the Biden-era OFCCP will follow an enforcement strategy more akin to that employed during the Obama years.
Our comparison is based on a review of enforcement data posted by the Labor Department (DOL) that summarizes OFCCP’s enforcement activities covering the Obama Administration for fiscal years (FYs) 2009-2017 and the majority of the Trump Administration’s term for FYs 2018-2020. The data are derived from three sources: (1) OFCCP’s online summary of its enforcement accomplishment data; (2) OFCCP’s Freedom of Information Act (FOIA) Library, with its summary of completed Conciliation Agreements (CAs) by fiscal year; and (3) DOL’s Data Enforcement Data Catalog, which publishes data from DOL’s various enforcement agencies, including OFCCP.
Members of the Center for Workplace Compliance (CWC) can read more here.