NT Lakis attorneys filed detailed written comments this week with the White House Office of Management and Budget (OMB) expressing reservations regarding any executive or congressional action that would fold the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) into the Equal Employment Opportunity Commission (EEOC).

The budget request sent by President Trump to Congress to fund government operations in fiscal year (FY) 2018 (October 1, 2017, to September 30, 2018) includes a proposal to merge OFCCP into the EEOC by the end of FY 2018.  Our comments, which were filed in response to Executive Order (E.O.) 13781, Comprehensive Plan for Reorganizing the Executive Branch, recommend that rather than merge the two agencies, the administration use this opportunity to implement much-needed reforms at both the EEOC and OFCCP.

In support of our recommendations, we point out that the legal and operational challenges involved in combining the two agencies likely would outweigh any practical benefits that might flow from the merger.

At the same time, recognizing that the administration may elect to proceed with the proposed merger, we also offer a number of specific recommendations for consideration that we believe would help to minimize the almost certain disruption that will occur.

Members of the Equal Employment Advisory Council (EEAC) can read more here.