Although no copy has yet been made available, OFCCP has announced that the Office of Management and Budget (OMB) has approved a revised scheduling letter and the itemized listing of documents and data required to be submitted at the outset of an OFCCP desk audit.

According to the Notice, the new scheduling letter will contain a number of substantive changes:

  • Individualized Compensation Data:  Most significantly, contractors may no longer submit annualized, aggregate compensation data. Rather, contractors must provide individualized employee compensation data as of the date of the workforce analysis in their AAP, including job title, job group and EEO-1 category.
  • Definition of Compensation:  Compensation data to be submitted now includes hours worked, incentive pay, merit increases, locality pay, and overtime.
  • Job Group or Job Title, But Not Both:  Contractors may continue to submit personnel activity data by Job Group or Job Title.  The scheduling letter amendments proposed in 2011 would have required submission of data by both Job Group and Job Title.
  • Minority Sub-Groups:  Rather than identifying applicants and employees by “minority” and “non-minority,” contractors must provide specific race or ethnicity for each using the five categories of the Uniform Guidelines on Employee Selection Procedures.
  • VEVRAA & Section 503 Changes:  The revised scheduling letter incorporates the changes to the VEVRAA and Section 503 regulations, including new data collection, recordkeeping and reporting requirements.
  • Electronic format:  Data must be provided electronically if it is maintained in an electronic format which is “useable and readable.”

As soon as we have the opportunity to review the new scheduling letter and itemized listing we’ll provide a copy and an updated analysis so stay tuned for more.

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Photo of Laura A. Mitchell Laura A. Mitchell

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with…

As co-leader of the firm’s ESG group, Laura Mitchell partners with her clients to evaluate, set, achieve and monitor their organizational culture and human capital goals. She focuses her practice on data analytics, including pay equity and other employee analytics, working side-by-side with employers to build programs that benefit employees and create a stable, high-functioning workplace. Understanding that an inclusive, values-based culture provides a crucial competitive advantage in the modern workplace, Laura enjoys counseling companies on the development of proactive and equitable pay and diversity practices.

In Laura’s version of the reimagined workplace, attention to human capital issues, especially DEI and pay equity, would be the rule rather than the exception nationwide and she works with companies across all industries—both new and well-established multi-national organizations of all sizes—to realize this vision for her clients’ ongoing success. She helps clients understand all issues across the spectrum of their journey, helping to establish regular analyses as well as counseling organizations on implementation and compliance obligations, where applicable. Committed to putting her clients’ organizational goals first and foremost, Laura views herself as an extension of her clients’ team, responsible for providing proactive guidance and engaging in transparent, ongoing communication.

Laura also represents companies in OFCCP matters, preparing for and defending OFCCP audits, and counseling employers on issues stemming from OFCCP regulations. She personally oversees the development of hundreds of Affirmative Action Plans for clients each year and is intimately involved in the defense of OFCCP audits. Her approach to compliance is one of facilitation and conciliation while simultaneously advocating in the best interests of her clients.