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OMB Approves Revised OFCCP Scheduling Letter

Client Alert | 1 min read | 10.03.14

Significant changes are just over the horizon for federal contractors and subcontractors, as OMB has approved the revised Scheduling Letter and Itemized Listing proposed by the Office of Federal Contract Compliance Programs. As further explained in the linked alert, the revised Scheduling Letter will require contractors, at the outset of a compliance review, to submit to OFCCP individualized compensation data, personnel activity data broken out by each racial subgroup (rather than in two groupings, minorities and non-minorities), and additional materials to demonstrate compliance with the new Veterans' Readjustment Assistance Act and section 503 of the Rehabilitation Act regulations that became effective earlier this year.


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Client Alert | 3 min read | 04.25.24

JUST RELEASED: EPA’s Bold New Strategic Civil-Criminal Enforcement Collaboration Policy

The Environmental Protection Agency’s (EPA’s) Office of Enforcement and Compliance Assurance (OECA) just issued its new Strategic Civil-Criminal Enforcement Policy, setting the stage for the new manner in which the agency manages its pollution investigations. David M. Uhlmann, the head of OECA, signed the Policy memorandum on April 17, 2024, in order to ensure that EPA’s civil and criminal enforcement offices collaborate efficiently and consistently in cases across the nation. The Policy states, “EPA must exercise enforcement discretion reasonably when deciding whether a particular matter warrants criminal, civil, or administrative enforcement. Criminal enforcement should be reserved for the most egregious violations.” Uhlmann repeated this statement during a luncheon on April 23, 2024, while also emphasizing the new level of energy this collaborative effort has brought to the enforcement programs....

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