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OFCCP Moves To Eliminate Burdensome EO Survey And Offers "Grace Period" For Compliance With Internet Applicant Rule

Jan.27.2006

On January 20, 2005, the Office of Federal Contract Compliance Programs issued a notice of proposed rulemaking (http://www.dol.gov/esa/regs/fedreg/proposed/
2006000646.pdf
), finally moving to eliminate the burdensome EO Survey -- as the government contracting community has been urging for years. OFCCP is in the process of developing a new system for selecting audit targets.

The OFCCP has also announced that it will not delay implementation of the "Internet Applicant" rule, but will observe a 90-day "grace period." For 90 days following February 6, 2006, OFCCP will not cite a contractor for a purely technical recordkeeping violation for failure to comply with the Internet Applicant final rule, provided that the contractor (1) demonstrates that it is taking reasonable steps to update its systems to comply with the rule, including a projected date of compliance, and (2) collects and maintains records according to the established procedures consistent with OFCCP's recordkeeping requirements that preexisted the Internet Applicant final rule, i.e., 41 CFR 60-1.12.

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Kris D. Meade
Partner – Washington, D.C.
Phone: +1 202.624.2854
Email: kmeade@crowell.com
Rebecca L. Springer
Counsel – Washington, D.C.
Phone: +1 202.624.2569
Email: rspringer@crowell.com