• Program Overview

    The Equal Opportunity (EO) Contractor Compliance Program (EOCCP) is responsible for ensuring that prime contractors and subcontractors performing work on NCDOT's Federal-aid highway construction projects comply with the nondiscrimination and affirmative action requirements outlined in the FHWA-1273 Required Contract Provisions. The EOCCP assures this through three key activities:

    • Conducting EO compliance reviews of primes and subcontractors;
    • Facilitating training in a variety of formats, and;
    • Providing technical assistance to contractors and NCDOT staff.

    Contractor Obligations

    Section II, Nondiscrimination of the FHWA-1273 outlines a contractor's minimum Equal Employment Opportunity (EEO) requirements, with the intent of ensuring the full participation of minorities and women in a contractor's workforce. These EEO provisions apply to all Federal-aid highway construction contracts of $10,000 or more, regardless of tier, and all employment practices (e.g., recruiting, hiring and firing, training, promoting, compensation and benefits, selection and retention of subcontractors).

    To comply, Federal-aid contractors must have a documented EEO Program that includes the following:

    • An EEO Policy Statement
    • Designation of an EEO Officer
    • Records of EEO-related meetings
    • Required Posters and Other Disseminated Materials
    • A Direct and Systematic Recruitment Process
    • Evaluations of Wages and Personnel Actions
    • Training and Promotions that reflect Equal Opportunity
    • Reasonable Accommodations for Disabled Applicants and Employees
    • Monitoring Subcontractors' Compliance with EO/EEO
    • Affording EO/EEO to Disadvantaged Business Enterprises (DBE) irrespective of Project DBE Goals
    • Maintaining EEO-related Records and Reports
    • Maintaining Nonsegregated Facilities (Section III of the FHWA-1273)

    Annual 1391 Reporting

    Contractors on Federal-aid projects must submit an Annual EEO Report (FHWA For​m​ 1391) each July for the duration of the project, indicating the number of minority, women, and non-minority group employees currently engaged in each work classification and training program required by the contract. This information is to be reported for all active Federal-aid construction projects. Appropriate sanctions may be enforced for contractors failing to report, such as withholding of progress payments. 


    • All prime contractors and subcontractors with Federal-aid contracts of $10,000 or more.
    • Subcontractors are required to submit their reports to the prime contractors.


    • The last full payroll period ending in July. Do not report any other payroll period in the month of July. A full payroll period is seven (7) days.
    • If the federal contract is active during this payroll period but no work was performed, contractors must submit a 1391 Report indicating "NO ACTIVITY".


    • If the prime contractor works during the month of July the prime and all subcontractors must file FHWA Form 1391.

    Click h​ere to get started on completing your FHWA 1391 Form, find detailed instructions, or access our FAQ list. ​

    Contact Information

    Contractors requiring assistance with their EEO obligations or help setting up a satisfactory EEO Program should contact the following: 

    ​Juan Conde
    ​Felicia Dickens

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