Andrew Turnbull
A primary focus of Andrew’s practice involves helping companies navigate employment issues that arise when doing business with the federal government, including advising on all aspects of OFCCP compliance, establishing strong ringfencing to avoid OFCCP coverage of non-contractor corporate affiliates, creating and implementing affirmative action plans, defending OFCCP audits, and conducting pay equity audits. Andrew is an active member and has served on the steering committee for the Washington Metro ILG for several years. He also speaks on a variety of employment topics, including at the NILG Conference in San Antonio in 2017.
Wednesday, Aug. 2
Workshop 3
Practical Tips for Navigating OFCCP Audit Requests
Andrew Turnbull and Sade Tidwell, Morrison & Foerster
With new OFCCP directives signaling less transparency and more aggressive audits, contractors need to understand how to appropriately respond to OFCCP’s requests for information (RFIs). Failure to do so can result in longer, more expensive audits and potential unnecessary adverse findings or enforcement proceedings. Attendees will learn about: (1) the legal authority and limitations for OFCCP RFIs; (2) common OFCCP RFIs; and (3) practical tips for mitigating risk and burden when responding to RFIs.
Thursday, Aug. 3
Workshop 2
Ringfencing – Shielding Non-Contractor Corporate Affiliates from OFCCP Coverage
Andrew Turnbull and Sade Tidwell, Morrison & Foerster
Many companies seek business with the federal government but want to avoid OFCCP jurisdiction over their corporate affiliates. With OFCCP now getting details about corporate families through the Contractor Portal, contractors need good ringfencing to avoid OFCCP seeking coverage of their non-contractor corporate affiliates. Attendees will learn about the legal framework for single entity and subcontractor status, common ways corporate affiliates become covered, and practical tips for establishing strong ringfencing to avoid coverage.
