Taft Stettinius & Hollister LLP
Patricia Anderson Pryor
September 24 2010
Today marks the 45th anniversary of Executive Order 11246, the Executive Order that requires employers that do business with the federal government, either directly or as a subcontractor, to undertake various affirmative action efforts. As the Office of Federal Contractor Compliance (“OFCCP”) holds anniversary parties to celebrate this milestone, it is an ideal time for employers to review whether they are a government contractor and, for those that are, to make sure their affirmative action policies and programs are up to date.
Every employer should review whether it has any government contracts or subcontracts. All too often the human resource professional, who should be administering the affirmative action obligations, is the last to know that the employer has entered into a contract with a federal government agency or contractor.
Moreover, in recent years, the OFCCP has expanded the universe of contractors routinely subject to its audits. For example, the OFCCP now takes the position that many healthcare organizations are federal contractors subject to the affirmative action requirements. See Health Care Providers and Other Companies May Unknowingly Be Government Subcontractors. The OFCCP is also increasing the attention it pays to construction contractors, due in part to the stimulus funds that have been spent.
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