Implementing Effective Contractor Compliance Programs
Click here to view the PowerPoint Presentation
Slide - 1
Slide # 1 contains three photographs:
the photgraph on the left depicts a female with a hard hat on reviewing plan drawings,
the middle photograph shows a male construction worker at a construction site. It appears he is working with a crane operator, the photograph shows two construction workers; one African-American and one who is a white male.
Slide - 2
OBJECTIVES
Program Overview
Effective Practices
Evaluation, Monitoring and Enforcement
Group Discussion
Slide - 3
PURPOSE
To ensure that federal contractors
and sub-contractors do not
discriminate in their employment
and contracting practices on
Federal-Aid Construction Projects.
Slide - 4
Slide # 4 depicts diversity; there are five different colored images of people with an additional individual depicted in a wheelchair.
EEO Program
•To ensure that all persons are afforded equal
or the same opportunities to participate in
federally assisted programs and activities
without regard to race, color, sex, age, religion,
national origin or disability.
•In both DOT's workforce and in the workforce of
contractors, subcontractors and material
suppliers engaged in the performance of
Federal-aid highway construction contracts.
Slide - 5
Slide # 5 depicts the scales of justice in the right lower corner.
PRIMARY AUTHORITIES
•23 USC 140 (a)
•State EEO Assurances
•23 CFR 230 - Subparts A, C and D
•FHWA 1273
Slide - 6
Slide # 6 contains a graphic of a law in decree form.
FHWA - 1273
Nondiscrimination Contract Provisions
1. EEO Policy Statement;
2. EEO Officer;
3. Dissemination of Policy;
4. Recruitment;
5. Personnel Actions;
6. Training and Promotion;
7. Unions;
8. Selection of Subcontractors, Procurement of
Materials and Leasing of Equipment; and
9. Records and Reports.
Slide - 7
Slide # 7 epicts a graphic of the word teamwork with the images of three individuals working together with pieces of a puzzle.
Partnership
To have an effective Equal Opportunity
Contactor Compliance Program (EOCCP)
•Cooperation
•Coordination
•Communication
Three major partners: FHWA, STA and
the contractor(s)
This is a preview only. Click Download Now to download the template.
Slide - 8
Slide # 8 depicts a male distributing folders to three participants.
Role & Responsibilities
• Contractor has to take all reasonable and
necessary steps to ensure that the terms and
conditions of its contract are fully met.
• STA is responsible for developing and
implementing effective processes to monitor
and determine contractor's compliance.
• FHWA has the stewardship, monitoring and
enforcement responsibility.
Slide - 9
Slide # 9 has a graphic of a male with a document to be signed, ie a compliance review report.
Types of Compliance Reviews:
•Project Specific
•Area-wide
•Consolidated
Slide - 10
Slide # 10 depicts a graphic of a man and a woman with hard hats on carrying construction plans.
Stages of Compliance Reviews
1. Review Scheduling;
2. Contractor Notification;
3. Preliminary Analysis/Desk Audit;
4. On-site Verification and Interviews;
5. Exit Conference;
6. Compliance Determination, and
7. Formal Notification.
Slide - 11
Slide # 11 contains a graphic of a gavel in the lower right corner.
Compliance Determination
•Voluntary Corrective Action Plan
•In Compliance - Notification Letter Sent
•Non Compliance - Corrective Action
Slide - 12
Slide # 12 has a graphic of a pencile and paper, ie a compliance review documents.
Corrective Actions
•Issue Show Cause Notice;
•Conduct mandatory meeting to discuss
Corrective Action Plan;
•Provide assistance and training;
•Accept CAP or Initiate Contract
Sanctions; and
•Conduct follow-up review.
Slide - 13
Slide # 13 contains a graphic in the upper right corner depicting a woman speaking to three other individuals in an office environment.
Effective Practices
• Conduct annual training for contractors, sub-contractors and consultants in each region;
• Training for Construction Managers;
• Provide annual on-line training for EEO
Officers;
• On-line Technical Assistance Guide, and
• Training for Contact Compliance Officer's
• CCOs Handbook.
Slide 14
Effective Practices
•Provide one-on-one assistance to resolve
individual problems;
•Conduct Technical Assistance one-on-one
meetings;
•Partner with the OFCCP to provide Contract
Compliance Review Training;
•Conduct Contractor's Roundtables;
•Develop and disseminate a statewide Recruitment
Resource Directory, and
•Award a Certificate of Continued Contract
Compliance.
Slide - 15
PROGRAM EVALUATION,
MONITORING AND ENFORCEMENT
Slide - 16
•Conducts Follow-up Reviews;
•Requires Contractors to submit monthly
progress reports;
•Provides Certificates of Compliance;
•Provides Weekly CCR Updates;
•Conducts Annual Review of CCR Program;
•Notifies FHWA of Contractors found to be in Non-Compliance to FHWA.
Slide - 17
Slide # 17 depicts a team making a presentation to a decision-maker. They are in an office environment, at a table with a pointer and chart and graph.
GROUP DISCUSSION
Slide - 18
Any questions
Sherree Hall Crowder, Affirmative Action
Program Director/Deputy Director
Civil Rights Office
Affirmative Action Program
505 Deaderick Street, Suite 1800
Nashville, TN 37243
615-741-5996 or 1-888-370-3647
Sherree.Hall.Crowder@tn.gov
http://www.tdot.state.tn.us/civil-rights/index.htm
Slide 19
THANK YOU
|
TRAINING
Top FHWA News
