On September 30, 2014, the Office of Management and Budget (OMB) approved the Office of Federal Contract Compliance Programs’ (OFCCP) new compliance evaluation scheduling letter and itemized listing. This new letter changes the materials that Federal contractors and subcontractors will need to submit to OFCCP at the beginning of an audit. The most significant changes are in the Itemized Listing portion of the letter.
Most of the changes to the scheduling letter are administrative in nature. References to outdated VEVRAA regulations have been removed. The 30-day response time for submitting requested items is unchanged. The letter also notes that OFCCP will be evaluating compliance with VETS-100A filings.
The new letter has some significant changes to the Itemized Listing section. These include:
- New sections for Section 503 and VEVRAA – focused on Affirmative Action Program (AAP) elements required under OFCCP’s new regulations
- Flexibility to submit employment activity by job title OR job group
- Requirement to submit employment activity by specific race/ethnicity categories (not just minority vs. non-minority)
- Overhaul of compensation submission requirements (data must be submitted on the individual employee level)
These changes reflect OFCCP’s new regulations and equal pay priorities. The new letter also maintains more reporting flexibility than the first draft of the proposed changes announced in 2011. Click here to view a copy of the letter.