The OFCCP’s Focus on Accurate EEO-1 Reporting
September 13, 2005
David J. Santeusanio- Boston
The United States Department of Labor’s Office of Federal Contract Compliance
Programs (OFCCP) has announced an initiative to establish a comprehensive
database of all federal contractors subject to Executive Order 11246. OFCCP has
used annual EEO-1 reports to determine whether a company was a federal
contractor. OFCCP has concluded, however, that many EEO-1 reports are incomplete
or inaccurate with respect to federal contractor status. As part of the effort
to establish a comprehensive database, OFCCP will carefully scrutinize the EEO-1
reports submitted to the government to check whether companies are accurately
identifying themselves as federal contractors.
OFCCP is now comparing its current database of federal contractors (as
generated by past EEO-1 reports) with lists of federal contractors compiled by
the General Services Administration and the Federal Procurement Data System.
Given OFCCP’s increased focus on accurate EEO-1 reporting, companies should
determine (1) whether they are a covered federal contractor and (2) whether they
have accurately reported their federal contractor status on the EEO-1 report.
There are significant consequences for inaccurate reporting. The consequences
may include penalties for intentional false statements and increased audit focus
and investigation by OFCCP. Given the upcoming deadline of September 30, 2005,
for filing EEO-1 submissions to the Equal Employment Opportunity Commission,
this is an appropriate time for companies to address carefully the accuracy of
their EEO-1 reports.
For more information, e-mail Paul Thomas or David Santeusanio at
paul.thomas@hklaw.com or
david.santeusanio@hklaw.com,
respectively, or call toll free, 1-888-688-8500.
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