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Category: Comment Letter

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has submitted comments to the Labor Department’s Office of Contract Compliance Programs (OFCCP) on its proposal to reinstate a monthly version of its long-discontinued Utilization Report (Form CC-257) for federal construction contractors and subcontractors. CWC’s comments support OFCCP’s efforts to improve the process for scheduling federal contractors for compliance evaluations but disagree that reinstating the CC-257 report will make the process more efficient.

CWC points out that OFCCP already has the necessary information about construction contractors. When federal construction contracts are awarded, agency contracting officers have to notify OFCCP of the contractor’s name, employer identification number, and project start and end dates, and prime contractors must report this information to OFCCP on Form CC-314. CWC believes that OFCCP should consult the resources it already has instead of reinstating an unnecessary and burdensome reporting requirement.

CWC’s comments also point out that Form CC-257 does not stem from a regulatory requirement.

If OFCCP decides to reinstate the CC-257, CWC urges the agency to make it an annual rather than a monthly report.

CWC members can read more here.

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