Earlier this year, the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) published a significant update to its Federal Contract Compliance Manual (FCCM), the internal document that details the procedures OFCCP compliance officers are expected to follow when conducting compliance evaluations and complaint investigations of federal contractors.

From a practical standpoint, while this was the first substantive update to the FCCM since 2013, by and large it simply incorporates OFCCP directives and amendments to Executive Order 11246 that have been issued or occurred since then, and which we have covered extensively in previous memos. This memorandum provides an overview of the updated manual, highlighting the most significant changes.

Please keep in mind that the FCCM is directed at OFCCP compliance officers (COs) – not federal contractors – and instructs them on how a compliance audit should be conducted. Thus it does not create any new law or regulatory authority nor does it directly create any new compliance obligations for federal contractors. Nevertheless, knowing what’s in the FCCM can be helpful because it puts a contractor on notice of what to expect from the CO during a compliance evaluation or complaint investigation.

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