Proposed Changes To Scheduling Letter Won’t Make OFCCP Audits More Efficient, CWC Comments

January 31, 2023

What's New

CWC has filed comments with OFCCP questioning its assertion that its proposed changes to the compliance audit scheduling letter and accompanying itemized listing will increase efficiency. We asserted that the current two-step evaluation process — in which contractors initially furnish aggregate information and OFCCP requests additional information only on an as-needed basis as the audit proceeds — better serves both contractors and OFCCP.

DOFCCP’s proposal would:

• Institute a second employee-level compensation data snapshot that would include compensation data for the employees of staffing agencies outside OFCCP’s immediate jurisdiction;
• Require contractors to document that they have evaluated their compensation systems for gender-, race-, and ethnicity-based disparities; and
• Significantly change the information that contractors must submit about promotions and terminations.

What It Means

We assert that OFCCP’s proposed changes would increase the administrative burden on federal contractors and the agency without improving the compliance evaluation process.

OFCCP will analyze the submitted comments and decide whether to revise its proposed Scheduling Letter changes before it submits a final proposal for approval to the White House Office of Management and Budget. Once that occurs, there will be an opportunity for the public to file comments directly with OMB.

What You Should Do

CWC members can discuss this issue during a Conversation Corner.

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