CWC filed comments with OFCCP in response to the agency’s announced intent to seek approval from the White House Office of Management and Budget to continue using its contractor portal and require users to enter the Unique Entity ID (UEI) for their parent company and each of the company’s establishments.
The portal is an online tool through which covered federal contractors and subcontractors annually certify their development and maintenance of affirmative action plans (AAPs). The contractor portal used to be called the Affirmative Action Program Verification Interface (AAP-VI).
CWC’s comments caution that UEIs are not an efficient method of identifying unique contracting entities. CWC pointed out that EEOC had to quickly modify its EEO-1 online filing system to permit federal contractors to enter UNAVAILABLE for the UEI in cases where no UEI existed or where the contractor was unsure which UEI to choose.
CWC’s comments also question OFCCP’s burden estimates and recommend revisions that would make the portal less burdensome. CWC suggested that the agency make the Unit ID an optional field or have the system assign it automatically, update the portal to directly accept bulk uploads from all contractors, and ensure that UEIs will be an optional field.