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FHWA Resource Center

What's New in Civil Rights

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

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