On Wednesday, February 13, OFCCP issued Directive 2019-04, outlining its plan to develop a Voluntary Enterprise-wide Review Program (VERP). VERP would affect organizations that have more than one establishment. The directive states that OFCCP will create a VERP framework that will recognize certain federal contractors and subcontractors for their high-performing corporate-wide equal opportunity and affirmative action efforts. Based on various criteria, organizations that apply and are accepted into the program would be placed into one of two tiers. These organizations would then be exempt from affirmative action compliance evaluations for either three or five years, depending on the tier into which they are accepted.

In order to participate in VERP, an organization must allow OFCCP to conduct compliance reviews at its corporate headquarters and a subset of the organization’s other establishments. Organizations will be required to meet certain criteria to be established by OFCCP that will demonstrate a commitment to providing equal opportunity and affirmative action on a corporate-wide basis.

The VERP program is only one of OFCCP’s recent efforts to engage in corporate-wide evaluations of federal contractors and subcontractors. The agency’s recent directive on Early Resolution Procedures (Directive 2019-02) also focuses in substantial part on multi-facility employers.

To read further about the expected application process and the obligations that maybe associated with this program, see https://www.dol.gov/ofccp/regs/compliance/directives/dir2019_04.html