ples, concepts, and steps contained in the standards for identifying, proving, and remedying discrimination. D. Ongoing Affirmative Action Program Obligations the contractor to identify problem areas (deficiencies) by organizational unit and job groups, these sections lack a clear definition of the potential problems to be addressed. The Task Force recommends that the two provisions be amended to incorporate the following concept: E. The contractor should conduct an indepth Purpose of Compliance Reviews Title 41 CFR 60-1.20 (a), which establishes the purpose of a compliance review, defines the process as a comprehensive analysis and evaluation of each aspect of the contractor's hiring, placement, training, governing the terms and conditions of employment, to determine compliance with the nondiscrimination and affirmative action provisions of the order. That definition of compliance reviews is premised upon an outdated perception of discrimination investigation. It assumes that the initial inquiry involves an extensive, time-consuming, inefficient investigation designed to uncover facts showing that specific practices are a pretext for employment discrimination against a protected group. The compliance review process should be redefined along the following lines: It (a compliance review) shall consist of CHAPTER 9 CURRENT ENFORCEMENT PROCESSES I. Introduction and Background Although Presidents Roosevelt and Truman both issued Executive orders forbidding discrimination by Government contractors, no onsite "compliance review" program was initiated until (and then only minimally) President Eisenhower's Executive Orders of August 1953 (10479) and September 1954 (10577). Those orders expanded the obligations of contractors to include nondiscrimination in "employment, upgrading, demotion or transfer; recruitment or recruitment advertising; layoff or termination; rates of pay and other forms of compensation and selection for training including apprenticeship." Although the President's Committee on Government Contracts (the administering agency) was given added authority by having the Vice President as chairman, it had no sanctions to apply in cases of noncompliance. However, a system of spot compliance reviews was initiated. President Kennedy's Executive Order 10925 af forded broader enforcement powers, including contract |