EEOC Adopts New Enforcement Plan
Cascade's Compliance Team
compliance@cascadeemployers.com
On June 4, 2026, the U.S. Equal Employment Opportunity Commission (EEOC) announced its new National Enforcement Plan (NEP), replacing its previous Strategic Enforcement Plan. The NEP outlines the types of cases the EEOC plans to focus on in its enforcement efforts moving forward.
Under the new plan, the EEOC states it will place greater emphasis on cases involving intentional discrimination, repeated or company-wide discriminatory practices, protection of vulnerable workers, religious accommodation issues, and cases addressing emerging legal questions. The plan also states that the EEOC intends to prioritize enforcement involving employment practices that consider protected characteristics, including certain diversity, equity, and inclusion (DEI) initiatives.
Although the NEP outlines the EEOC's enforcement priorities, it does not change existing employment discrimination laws or create any new compliance obligations for employers. Oregon and Washington employers, as well as employers in any other state, should continue to comply with applicable federal, state, and local anti-discrimination laws and ensure employment decisions are based on legitimate, nondiscriminatory business reasons.
July Compliance Reminder
Cascade's Compliance Team
compliance@cascadeemployers.com
Now that July 1st has passed, employers should confirm they have implemented the following changes:
Oregon Employers
Minimum Wage Increase
- Confirm minimum wage employees’ pay rates were updated to reflect Oregon's new minimum wage rates effective July 1st:
- Standard Minimum Wage: $15.55 per hour
- Portland Metro Minimum Wage: $16.80 per hour
- Nonurban Counties Minimum Wage: $14.55 per hour
- Verify payroll systems and timekeeping practices reflect the correct rate based on where employees perform work.
- Update your Oregon minimum wage poster to reflect the 2026 rates.
Washington Employers
Expanded Fair Chance Act Requirements
- Employers with 15 or more employees should review hiring practices to ensure compliance with the expanded Fair Chance Act requirements that took effect July 1st.
- Review and update employment applications, interview practices, and hiring procedures involving criminal history, and ensure hiring managers understand the new requirements.
In the News: When Off-Duty Conduct Impacts Employment
Cascade's Compliance Team
compliance@cascadeemployers.com
A recent news story involving a JPMorgan Chase DEI executive serves as a good reminder that off-duty conduct can sometimes have workplace consequences. After a viral video showed the executive dumping the contents of a city-owned commemorative Knicks-themed trash can onto the streets of NYC during the Knicks' NBA championship parade and later riding on the subway with the trash can, JPMorgan Chase confirmed that the employee was no longer with the company. In today's digital age, videos of off-duty incidents can spread quickly online, and employers may find themselves addressing conduct that occurs outside the workplace.
In general, private employers may take corrective action, up to and including termination, for off-duty conduct when there is a legitimate business reason to do so, such as when the conduct violates company policy, harms the employer's reputation, or negatively impacts the workplace. However, it is important to remember that some off-duty conduct is protected by federal, state, or local law, including employees' rights under the National Labor Relations Act to discuss workplace terms and conditions.
Since every situation is unique, employers should evaluate off-duty conduct on a case-by-case basis before taking corrective action. Employers should gather the facts, ensure the conduct is not legally protected, determine whether there is a legitimate business reason for taking action, and apply policies and past practices consistently.
If you have any questions, please do not hesitate to reach out to us. We’re here for you!
Start Strong: Take Advantage of Your Complimentary HR Practices Assessment
Sheryl Kelsh, Membership Development Manager
membership@cascadeemployers.com
As a Cascade member, you have access to a valuable opportunity to participate in a Human Resource Practices Assessment, commonly referred to as an HRA. This complimentary member benefit is designed to provide real-time feedback on your current HR practices, identify potential areas of risk, and help you better understand the resources available to support your organization.
For many new members, the HRA is an excellent first step in getting the most out of your Cascade membership. However, this resource is not limited to new members. If your organization has not yet completed an HRA, or if it has been some time since your last assessment, this is a great opportunity to take a fresh look at your HR structure and priorities.
The HRA process is simple and straightforward. First, you will receive a link to an online survey that gathers important information about your current HR practices, policies, compliance areas, and overall structure. Once the survey is completed, one of Cascade’s HR Consultants will follow up to schedule a personalized Zoom meeting with you.
During that conversation, the consultant will review your responses, discuss any areas that may need attention, and provide practical recommendations based on your organization’s needs. This session is also a great opportunity to ask questions, talk through current HR challenges, and learn more about the Cascade resources that may be most helpful to you.
With local, state, and federal employment regulations continuing to evolve, the HRA can serve as a helpful checkpoint for your organization. It can assist with compliance awareness, project planning, policy updates, and identifying where additional support may be beneficial. Whether you are building out your HR function, reviewing existing practices, or simply looking for guidance on where to focus next, the HRA offers a meaningful starting point.
To request your Human Resource Practices Assessment, please contact Sheryl Kelsh.
Hot Compliance Question
Cascade Compliance Team
compliance@cascadeemployers.com
Question: My employee hurt their back while moving over the weekend. Can I prohibit them from filing a workers' compensation claim since I know they weren't injured at work?
Answer: No, employees always have the right to file a workers’ compensation claim. Discouraging, preventing, or interfering with an employee’s ability to file a claim is unlawful. Once a claim is submitted, the workers’ compensation insurer is responsible for determining whether the injury is work-related and whether the claim will be accepted or denied.