The American Staffing Association has published a revised issue paper addressing staffing firms' obligation to comply with federal record-keeping requirements administered by the U.S. Equal Employment Opportunity Commission and the record-keeping and affirmative action regulations of the Office of Federal Contract Compliance Programs (an agency of the U.S. Department of Labor).
Revised under the auspices of affirmative action compliance expert Valerie Hoffman, partner at the law firm Seyfarth Shaw, the paper sets forth the ASA position regarding the extent to which the OFCCP and EEOC rules apply to temporary employees. Because this issue has not definitively been resolved by courts, the paper also examines whether OFCCP and EEOC, under the Obama administration, would be likely to take the position that such rules do apply.