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Rosemary Cox

Rosemary Cox, M.S.

Senior Consultant
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Rosemary Cox is a Senior Consultant at DCI Consulting Group, headquartered in Washington, DC, where she provides consultation specific to equal employment opportunity and affirmative action statutes and regulations. Her area of expertise includes AAP reporting, recruitment process and metrics, strategic audit discussions, mock audits, compliance and diversity/inclusion training and strategy.

Rosemary holds a MSA in Human Resources from Central Michigan University, has senior certifications through, SHRM, HRCI, AAAED and the State of Ohio. With 20 years of human resource compliance experience, she supports a variety of corporations in various industries, writes for the DCI Blog, conducts webinars and training.

Rosemary is a member of several professional organizations including the Ohio Industry Liaison Group (OILG), Society for Human Resource Management (SHRM), American Association for Access Equity and Diversity (AAAED).

Rosemary Cox ’s Recent Posts

President Trump recently released two items of interest to this industry: 1) an Executive Order on March 13th directing the Director of the Office of Management and Budget to propose a plan with the assistance of each agency to reorganize the executive branch; and 2) a proposed budget on March 16th or Fiscal Year (FY) 2018.  Both of those documents propose improved efficiency and, more importantly, reduced budgets. Specifically, the President’s proposal includes a 20.7% budget cut to the Department of Labor (DOL); see table below.

While the President’s proposed budget does not specifically name the OFCCP within its potential cuts, with a 20.7% overall reduction to the DOL budget, we can only assume that cuts will come to the OFCCP as it’s an agency within the DOL. The proposal does discuss the strengthening of the military and assistance for Veterans; with that in mind, we can assume that VEVRRA will continue to be a focus going forward.

2018 Discretionary Overview by Major Agency

It is unknown how the budget will play out for the OFCCP without a Labor Secretary in place and with the Executive Order mandating a proposed plan for the reorganization of the executive branch.   Historically, a budget reduction for OFCCP meant changes in a) staffing and b) travel funds, which impact enforcement activities. Hiring freezes mean no additional experts (statisticians, economists, I/O psychologists) for specific enforcement areas, and less money to spend on litigation; a staff reduction would mean fewer resources for day-to-day compliance review work. A reduced travel budget means fewer on-site reviews and less OFCCP participation in events such as conferences that would require more than local travel.

DCI will keep you informed of any new developments.

By Rosemary Cox, Senior Consultant at DCI Consulting Group

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DCI has just learned that OFCCP began to send out audit scheduling letters on March 17th.  At this time we are not certain how many were sent out, but we do know that 800 CSALs (Corporate Scheduling Announcement Letters) were sent to contractor establishments last month.  It is critical that corporate compliance representatives notify individual establishments in their organization to be on the look-out for any official OFCCP correspondence.  If you did receive a scheduling notice, please notify DCI immediately so that we can assist you with the audit process.

To read the audit distribution notice, please click here.

By Rosemary Cox, Senior Consultant at DCI Consulting Group

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What does this mean for you?  The current form expires on January 31, 2017, so Federal Contractors will need to update their self-id forms.  For some of you this may require a system update and for others it may simply be using the new form.  Since the new form was just released today contractors should not be held in violation for utilizing the old form, however, systems should be changed as soon as possible.

The new form is located on the Department of Labor/OFCCP website

As a reminder, the voluntary self–identification form is an OMB–approved form and, as such, its content cannot be altered or changed.

By Rosemary Cox, Senior Consultant at DCI Consulting Group

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On September 30, 2016, the Office of Management and Budget (OMB) advanced a proposal with a notice to the Federal Register to create a new racial or ethnic category.

Currently people from the Middle East and North Africa are considered “white” in the U.S. Census.  The proposed change could add a new category to the list. Middle Eastern or North Africa, or MENA, is broader in concept than Arab (an ethnicity) or Muslim (a religion).  It would include anyone from a region of the world stretching from Morocco to Iran, including Syrian and Coptic Christians, Israeli Jews and other religious minorities.

What will the data will be used for once collected?  According to the OMB, the data will be used for:

  • Enforcing the requirements of the Voting Rights Act;
  • Reviewing State congressional redistricting plans;
  • Collecting and presenting population and population characteristics data, labor force data, education data, and vital and health statistics;
  • Establishing and evaluating Federal affirmative action plans and evaluating affirmative action and discrimination in employment in the private sector;
  • Monitoring the access of minorities to home mortgage loans under the Home Mortgage Disclosure Act;
  • Enforcing the Equal Credit Opportunity Act;
  • Monitoring and enforcing desegregation plans in the public schools;
  • Assisting minority businesses under the minority business development programs;
  • Monitoring and enforcing the Fair Housing Act.

So what does this mean for Federal Contractors?  Well, we have plenty of time to think about it as it would not go into effect until the 2020 Census.  If this passes contractors will most likely need to change their paper and online self-id forms to include the new race categories and re-survey the workforce.

The good news is that maybe with these changes, the OFCCP and the EEOC will sync their race/ethnicity categories. Only time will tell.

By Rosemary Cox, Senior Consultant at DCI Consulting Group

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Really, I Come Here for the Food: Sex as a BFOQ for Restaurant Servers

Michael Aamodt, Principal Consultant at DCI Consulting Group, wrote an article featured in SIOP’s TIP publication, January 2017.

Recent Blog Posts

Fiscal Year 2018 Budget Proposes Merger of OFCCP and EEOC

The Department of Labor’s Fiscal Year 2018 (FY2018) budget proposal was released today, May 23, 2017.  The budget outlines the initiatives and priorities of the new administration, and as predicted by DCI, recommends merging the Office of Federal Contract Compliance Programs (OFCCP) and Equal Employment Opportunity Commission (EEOC) by the end of FY2018.

The proposed budget indicates that the consolidation will provide efficiencies and oversight.  Additionally, the proposed budget allots $88 million for OFCCP, a decrease of $17.3 million from Fiscal Year 2017.  The main cut to the budget appears to be headcount, with a proposed 440 full-time equivalent (FTE) headcount, a reduction from 571 FTEs.  Some other interesting items that have

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