OMB Approves Changes to OFCCP Scheduling Letter

Proskauer - Government Contractor Compliance & Regulatory Update
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The Office of Management and Budget (“OMB”) has approved changes to the current contractor scheduling letter and itemized listing used by OFCCP in compliance reviews. The new letter is expected to be released today. OFCCP proposed the changes to its scheduling letter three years ago.

OFCCP announced today OMB’s approval of the following changes to the scheduling letter:

(1) contractors will be required to submit personnel activity by specific ethnicity/race;

(2) contractors will be required to submit individualized employee compensation data as of the date of the workforce analysis in the Affirmative Action Program, including the employee’s job title, job group and EEO-1 category, and total compensation (including hours worked, incentive pay, merit increases, and locality pay, and overtime); and

(3) the letter will be updated to include new requirements under VEVRAA and Section 503.

OMB did not approve OFCCP’s request that contractors be required to submit prior year and updated personnel activity by both job group and job title. It is unclear at this point when OFCCP will begin using the new scheduling letter.

The text of the OMB’s approval notice can be located here.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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