Federal contractors have numerous non-discrimination and affirmative action obligations under Executive Order 11246, the Vietnam Era Veterans’ Readjustment Assistance Act (“VEVRAA”) and the Rehabilitation Act, including the preparation of annual written affirmative action plans. These obligations are enforced by the Department of Labor’s Office of Federal Contract Compliance Programs (“OFCCP”), which is currently headed by Patricia A. Shiu. Since Shiu was appointed director in August of 2009, the OFCCP has been extremely active, increasing contractors’ affirmative action requirements and expanding the OFCCP’s role in enforcing these requirements. The OFCCP’s recent efforts are notable because they will likely increase contractors’ data collection and reporting requirements. Several of these actions are described below.
