OFCCPs Federal Contract Compliance Manual Enters the 21st Century
By JON A. GEIER, MARIA A. AUDERO & HEATHER A. MORGAN
The new FCCM is a streamlined, modernized, reorganized, and improved tool for the contracting community. Substantial parts of the content are unchanged, but OFCCP has taken the opportunity to include new content that reflects its recent focus on hiring, overrepresentation of both protected and non-protected groups, and corporate policies. This Article will focus primarily on the Desk Audit and on changes to the definitions that are of most immediate and general interest.