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

Client Alert | 1 min read | 01.27.06

On January 20, 2005, the Office of Federal Contract Compliance Programs issued a notice of proposed rulemaking, 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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Client Alert | 2 min read | 07.15.26

CMMC Phase II Suspension Requires Reconsideration of Such Requirements in Solicitations

As discussed in more detail here, the U.S. Department of War (DoW) recently issued a memorandum (Memo 26-P-1023, dated July 13, 2026) directing the immediate suspension of Cybersecurity Maturity Model Certification (CMMC) Phase II requirements (Level I and II self assessments are still permitted). Significantly, the memo directs that “all pending and future CMMC implementation milestones across DoW solicitations and contracts are held in abeyance until further notice.” Moreover, the DoW issued a memorandum on implementing these requirements (available here), directing agencies to issue amendments removing CMMC Level 2 and 3 requirements from active solicitations “as soon as practicable.” Contractors should monitor the government’s compliance with this requirement and should be prepared, if needed, to file a bid protest to protect their rights....

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