Back in May, the OFCCP proposed some pretty significant changes to its scheduling letter and itemized listing. The comment period on these changes was open until July 11, and numerous commenters expressed serious concern over the proposed changes. Many of the comments submitted were related to the broadened scope of information sought and the increased burden on employers that the changes would create.
Despite the comments, OFCCP has submitted its proposed changes to the scheduling letter and itemized listing virtually unchanged. Most of the issues raised during the comment period were dismissed by the Agency. Interestingly, OFCCP dismissed concerns regarding the amount of time and effort employers would be required to spend responding to the new requests; the Agency contents that the time required for response will actually decrease as a result of the proposed changes.
The most significant changes to the scheduling letter and itemized listing involve the policy and procedure documentation employers would be required to produce, the way in which employers group employees when reporting employment activity, and the compensation data that would be requested.
In this week’s installment of The Proactive Employer Podcast, we’ll be talking about these proposed changes and what they mean for employers with Carla Irwin. Ms. Irwin is the President of Carla Irwin & Associates; her firm specializes in developing and implementing Affirmative Action Programs for federal contractors.