The Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) is once again proposing extensive changes to the letter used to schedule federal contractors for compliance evaluations under the laws OFCCP enforces. If ultimately approved by the White House Office of Management and Budget (OMB), the revised scheduling letter will require contractors to submit additional data to the agency in conjunction with routine compliance reviews as well as corporate management compliance evaluations, increasing the total number of items in the Letter’s accompanying Itemized Listing from 22 to 26.
Among the more notable changes that OFCCP is asking for is a request for a second employee-level compensation data “snapshot,” one that would include compensation data for the employees of staffing agencies outside of OFCCP’s immediate jurisdiction; a new Item 22 that would require the contractor to submit “documentation that the contractor has satisfied its obligation to evaluate its compensation system(s) to determine whether there are gender-, race-, or ethnicity-based disparities;” and a revised Item 18 (new Item 20) that makes significant changes regarding the submission of a contractor’s promotion and termination activity.
Members of the Center for Workplace Compliance (CWC) can read more here.