OFCCP Issued Proposed Scheduling Letters for Focused Reviews on Promotions and Accommodations…But They Are Not What You Expected

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The Office of Federal Contract Compliance Programs (“OFCCP”) has now sent two proposed audit Scheduling Letters to the Office of Management and Budget (“OMB”) seeking OMB’s approval for OFCCP to use them to launch “focused reviews on promotion” and “focused  reviews on disability and religious accommodations.” But neither of these two new audits is in fact what the name states: rather, both are full scope compliance reviews also covering Executive Order 11246 AAP compliance, failure to hire and promote systemic discrimination analyses, involuntary termination analyses, full-on compensation analyses and Section 503 and VEVRAA AAP compliance and

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