As we look forward to what is to come in 2015, it's important to reflect on where we have travelled. The ride was bumpy for federal contractors in 2014, and perhaps best described as "under construction" for Office of Federal Contract Compliance Programs (OFCCP). The agency implemented or proposed a series of new regulatory requirements, placed new directors in several regional field offices, and refined its investigative procedures to more aggressively root out unlawful discrimination.
Only the President may have been busier, issuing a whopping number of new executive orders or memorandums applicable to federal contractors in 2014, including:
Executive Order 13658, which established a minimum wage for a limited number of federal contracts (The Department of Labor's (DOL) Wage and Hour Division, not OFCCP issued regulations);
Executive Order 13665, which prohibits federal contractors from discharging or otherwise discriminating against their employees and job applicants for discussing, disclosing, or inquiring about compensation;
Executive Order 13672, which amended Executive Order 11246 to prohibit discrimination on the basis of gender identity and sexual orientation;
Executive Order 13673, which requires federal contractors to disclose recent labor law violations, including wage and hour, safety and health, discrimination, family and medical leave, and collective bargaining violations, as part of the federal contracting process, among other requirements; and
Presidential Memorandum "Advancing Pay Equality Through Compensation Data Collection," requiring the DOL to evaluate and propose a rule requiring federal contractors and subcontractors to submit compensation data to the federal government.