NT Lakis has filed written comments with the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) regarding the agency’s proposed procedures for resolving alleged “material” violations found during a compliance evaluation.

Although our comments support OFCCP’s goal of codifying the practice of using Predetermination Notices (PDNs) and Notices of Violation (NOVs) as tools to identify and resolve potential indicators of discrimination, and to more clearly articulate how the agency will use statistical and nonstatistical evidence in assessing whether material violations have occurred, we recommend that OFCCP further revise its proposal to ensure that the final rule is consistent with both current agency practice and Title VII principles.

Members of the Center for Workplace Compliance (CWC) can read more here.