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The Federal government fiscal year began October 1st and there have already been big changes in reporting and oversight at the Office of Federal Contract Compliance Programs (OFCCP).
The long-awaited revised Scheduling Letter and Itemized Listing was approved by the Office of Management and Budget (OMB) this week and published in the Federal Register on September 30th. The Itemized Listing, used in conjunction with the Scheduling Letter, identifies the documents and information that contractors must provide for the desk audit phase of an OFCCP compliance evaluation.
While the Scheduling Letter itself brought non-controversial changes for conformity with recent regulatory changes, the Itemized Listing is an enormous departure from the current desk audit data submission requirements. Of note are the following:
- Compensation data will now be required on an individual employee basis with each AAP submission. Previously, only average compensation by male/female, minority/non-minority groupings was required.
- Compensation data for contract employees has been added to that of full-time, part-time, per diem, temporary and day laborers.
- In addition submitting base wages for each employee, bonuses, incentives, commissions, merit increases, locality pay, overtime and number of hours worked in a typical workweek will be required in separate columns/fields.
- Compensation manuals, policies and practices are now required to explain each of the compensation programs listed above.
The revised Itemized Listing continues to permit contractors to submit employment activity data by either job group or job title, but race and ethnicity using speciic racial/ethnic sub-categories rather than minority and non-minority will now be required. Among the other additional items required are: an evaluation of the effectiveness of outreach and recruitment of qualified individuals with disabilities and protected veterans; accommodations requested, resolved, and documentation; assessment of personnel practices; and the most recent assessment of physical and mental qualifications, including the date of assessment and next scheduled assessment.
The OFCCP also published that it will not schedule any Supply and Service compliance reviews until after October 15, 2014 to permit contractors a period in which to become familiar with these requirements.
In the OMB approved renewal, the agency is requiring contractors to provide the data electronically but only if they maintain it in an electronic format that is useable and readable.
Click here to link to the OMB site to view the new scheduling letter, compliance check letter and new Itemized Listing.
Source: Office of Management and Budget's Office of Information and Regulatory Affairs (OIRA)
This information is intended to be educational and should not be considered legal advice on any specific matter. |
