1A07 Novel Issues

Novel issues are those that are unfamiliar, unique or fall outside the norm. Periodically, the OFCCP national office will identify certain novel issues and develop specific procedures to address them. Investigators may encounter novel issues in a compliance evaluation. When this occurs, they must, in coordination with their supervisor and regional and national office, determine the approach to use, data to obtain and analyses to conduct before recommending a finding of compliance or noncompliance. Novel issues include those not routinely addressed, like a publicly announced contractor preference in employment to Indians and Native Americans living on or near an Indian or Native American Reservation. In this example, the Investigator and supervisor would coordinate with the OFCCP’s Indian and Native American Employment Rights Program (INAERP) within the Division of Policy and Program Development (DPPD) to address the impact of the contractor’s use of a publicly announced preference in employment to Indians and Native Americans. Novel issues could also include compliance evaluations that involve coordination with the Division of Enforcement (DOE) on issues like testing, multi-establishment contractors, and complex or unusual compensation issues.