L36.2:C76/prelim

Preliminary Report

On March 31, Assistant Secretary Elisburg appointed a
Special Task Force to review the Office of Federal
Contract Compliance Programs (OFCCP) and develop a plan
for its improvement. Weldon J. Rougeau assumed the
position of Chairman of the Task Force upon his appoint-
ment to the position of Director, OFCCP, on June 5. The
preliminary findings and recommendations of the Task Force
are contained in the enclosed Preliminary Report on the
Revitalization of the Federal Contract Compliance Program.
In preparing the report, the Task Force examined all
available past studies and surveys of the Federal Contract
Compliance Program and a great many which have dealt with
other Federal equal employment agencies. They also examined
thousands of documents from the public which contain comments
solicited on the full range of issues treated in regulations
proposed by the Department of Labor last fall and they have
carefully analyzed the volumes of testimony presented by the
public this past winter in the public hearings conducted in
New York, Chicago, Atlanta, and Los Angeles. Finally, exten-
sive interviews were conducted with OFCCP staff, select
personnel of the compliance agencies, and, in addition,
informal consultations were undertaken with client and
regulatory groups, including lay persons as well as selected
representatives of the plaintiff's and defendant's bar.

From these sources the Task Force finds a single overriding concern. That concern relates to whether the Department and

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the OFCCP can transform the Federal Contract Compliance
Program into an EEO enforcement institution built upon
basic policies, approaches, standards, and processes
which fully meet fundamental management concepts and
client group expectations of efficiency and effectiveness
as well as certain fundamental legal concepts and legiti-
mate contractor expectations of fairness. In its recom-
mendations the Task Force presents a conceptual game play
plan by which that objective can be accomplished. We
are advised that the game plan is equally applicable
whether the Program remains with the Department of Labor
or is eventually made a part of any new Federal con-
figuration of EEO enforcement activities.

To assist in assuring maximum possible public input, the
Task Force prepared the report in two segments. The first
segment contains a summary of the findings and recommenda-
tions and is written with the lay audience in mind. The
second segment develops the historical perspective and
provides those technical details which are of interest to
client groups, regulated groups, and practitioners who
have expressed an interest in providing input of greater
depth. For this latter purpose, the Task Force also has
incorporated an appendix containing OFCCP's current regula-
tions and related documents.

Since our responsibility for the Task Force was administrative, we have not attempted to guide the judgment of the Task Force. Therefore, we are withholding our recommendations regarding the report until public comment has been received and analyzed. At that time, a final OFCCP report, with recommendations and a proposed implementation schedule, will be presented to you.

We are aware that one of your highest priorities is to improve the administration and strengthen the enforcement of the Department of Labor's equal employment opportunity

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