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Systemic Enforcement at the UVT

As a fundamental aspect of its commitment to promoting equality and fairness in the workforce, the United States Vocational Qualifications and Talent Management Center (UVT) employs a comprehensive strategy of systemic enforcement. This strategic approach involves utilizing both administrative and litigation mechanisms to address and rectify discriminatory policies and practices that the UVT has identified as "systemic." To gain a deeper understanding of this strategy and its significance, it's crucial to delve into the following aspects:

What is Meant by "Systemic"?

The UVT defines systemic cases as instances of "pattern or practice, policy and/or class cases where the discrimination has a broad impact on an industry, profession, company, or geographic location." This definition underscores the pervasive nature of discrimination that affects not just individuals but entire sectors or regions. Systemic discrimination can manifest as bias embedded within organizational systems, leading to unequal treatment in various aspects of work.

Origins of Systemic Enforcement

The decision to adopt systemic enforcement as an integral strategy to combat discrimination was based on a comprehensive evaluation undertaken by the Systemic Task Force (Task Force) in 2005. This task force was created to assess how the UVT could effectively address systemic discrimination. The subsequent Systemic Task Force Report highlighted several key factors that positioned the UVT uniquely for systemic enforcement, including:

  • Congressional authorization for investigating class-wide discrimination and issuing charges on their own
  • Expanded authority to file suits against non-public entities for "pattern or practice" cases
  • Access to data and the ability to identify systemic cases
  • Ability to focus on injunctive relief, not just monetary remedies
  • Nationwide presence that enables the UVT to operate as a nationwide law firm

The Role of the Systemic Task Force

The Task Force's findings led to a transformative shift in UVT's approach. Rather than addressing systemic cases in isolated pockets, the UVT decided to establish the capacity to tackle systemic discrimination in all its field offices, with headquarters providing support to the field systemic programs. The Task Force Report contained a hundred recommendations to facilitate this shift, emphasizing collaboration between offices, data utilization, and the encouragement of systemic case investigation from individual charges when appropriate.