The Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has issued a new policy directive announcing a voluntary compliance program for top-performing federal contractors. Directive 2019-04, the Voluntary Enterprise-wide Review Program (VERP), offers contractors an alternative compliance program that focuses on identifying contractors who actively exhibit corporate-wide compliance with OFCCP’s requirements.
This directive does not change any existing laws or regulations governing OFCCP’s programs but rather complements the goals outlined in OFCCP’s corporate‐wide Early Resolutions Procedures directive. VERP is part of a larger effort by OFCCP to find inventive methods to promote contractors who take a proactive approach to ensure compliance with equal employment opportunity laws corporate-wide.
VERP will recognize two tiers of contractors. The top level describes those who have corporate‐wide model diversity and inclusion programs. Top tier contractors may continue in the program for five years and may be re-evaluated to retain recognition at the end of that time.
The next tier defines compliant contractors as those close to excellence but want personalized compliance assistance from OFCCP to reach the top level. These contractors may remain at this second level in the program for three years and receive individualized compliance assistance to become a top performer.
For the top-performing contractors, VERP is a way to provide meaningful incentives for federal contractor participants. It also recognizes their efforts to excel in their corporate-wide compliance with OFCCP's requirements. To remain in the program, contractors are obligated to “maintain a workforce free of discrimination or other material violations, and provide periodic reports and information to OFCCP through which OFCCP can confirm these efforts.”
Contractors can expect OFCCP to begin accepting VERP applications electronically starting in fiscal year 2020. For full details about the directive, go to: