CWC has submitted comments to the Labor Department’s Office of Contract Compliance Programs on OFCCP’s proposal to reinstate a monthly version of its long-discontinued Utilization Report (Form CC-257) for federal construction contractors and subcontractors. CWC’s comments support OFCCP’s efforts to improve the process for scheduling federal contractors for compliance evaluations but disagree that reinstating the CC-257 report will make the process more efficient.
CWC asserts that OFCCP already has the necessary information about construction contractors—from CC-314 Forms filed by prime contractors and from federal agency contracting officers’ reports about construction contract awards, including contractor names, employer identification numbers, and project start and end dates.
CWC’s comments state that OFCCP should consult the resources it already has instead of reinstating an unnecessary and burdensome reporting requirement. CWC’s comments also point out that Form CC-257 does not stem from a regulatory requirement. If OFCCP decides to reinstate the CC-257, CWC urges the agency to make it an annual rather than a monthly report.