Equal Opportunity Survey—comments due December 6

The U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) proposes to survey federal contractors annually, according to the department’s October 5, 1999, Federal Register announcement. The new Equal Opportunity Survey will collect data reflecting personnel activity—applicants, incumbents, hires, promotions, and terminations—and compensation data. The National Center on Poverty Law and Women Employed urge you to submit comments in support of this proposal.

Background

. One of the most effective tools that the OFCCP has for expanding equal opportunity is the contract compliance program, which requires companies doing business with the federal government to abide by antidiscrimination requirements and take affirmative action to improve job opportunities for women and people of color. However, due to limited resources, the OFCCP conducts less than 4,000 compliance reviews per year out of a universe of 100,000 contractor establishments. Currently the OFCCP is able to collect only certain data, including wage data, when it is on site for a compliance review.

Impact

. For the first time in the history of the OFCCP, employers will be required to submit annual employment data to the OFCCP, whether or not the agency intends to schedule a compliance review. Approximately 60,000 contractors will be required to submit the Equal Opportunity Survey annually. The impact of this change is immense. Enforcement efforts will be able to target pay discrimination, as well as occupational segregation and other discriminatory practices, without having to uncover it first only in the course of a compliance review. More important, this new approach will encourage contractors to conduct self-audits and undertake proactive measures to ensure nondiscrimination and pay equity in their workplaces. Women Employed has been advocating this approach and particular methodology for over 20 years.

Comments on the proposed revisions are due by December 6, 1999,

via mail (see sample letter for address) or fax (202.693.1451). The proposal is long overdue and necessary to improve efficiency in enforcement efforts and accountability for federal contractors. We strongly urge you to submit comments and to encourage others to do so as well. We need widespread grass-roots support to counteract the strong opposition expected from the corporate community. Below is a sample letter that you may sign and mail or fax to the U.S. Department of Labor. Also, please mail or fax a copy of your submission to Nancy Kreiter at Women Employed, 22 W. Monroe St., Suite 1400, Chicago, IL 60603, or 312.782.5249 (fax).

We cannot stress enough how vital your action will be to the approval of the OFCCP’s proposal. Not only the substance of the comments submitted but also the sheer numbers of commenters supporting and opposing the proposal will influence final action on it. Thank you for your commitment to equal opportunity. If you have any questions, contact Nancy Kreiter, Women Employed, 312.782.3902.