It’s here.  OFCCP’s New Scheduling Letter and Itemized Listing has been released and is effective for any audits initiated today, October 1, 2014, and going forward.  OFCCP has announced, however, that it will not schedule audits from October 1 through October 15 to allow contractors time to “become acquainted” with the new scheduling letter and itemized listing.  We’ve learned from an official at OFCCP that the Agency is in the process of developing FAQs surrounding the new letter.  The FAQs should be released some time during this 15-day “audit moratorium.”

As we noted yesterday, the revised scheduling letter and itemized listing changes a number of the audit submission requirements.  Here’s a summary of the changes:

  • Compliance with the new veteran and disability regulations:
    • Results of the effectiveness of outreach evaluation;
    • Documentation of the audit and reporting system;
    • Data collection and analysis, including an additional six months if more than six months into the plan year;
    • Disability utilization analysis, including progress for the current year if more than six months into the plan year; and,
    • Veteran hiring benchmark, including progress for the current year if more than six months into the plan year.
  • Support Data:
    • Policy statements, employee notices and handbooks implementing the CBA;
    • All personnel activity data shall be submitted by sub-minority group (OFCCP lists the traditional 5 groups);
    • All unknowns shall be included in the submission; and,
    • Include a definition of promotion.
  • Compensation:
    • Employee-level (not summary) compensation data;
    • As of the WFA date;
    • Defined “employees” to include (FT, PT, contract, per diem, day labor, temporary);
    • For each, provide JT, EEO-1, JG and DOH;
    • Additional columns for bonuses, incentive, commissions, merit increases, locality pay, and OT; and,
    • Compensation policies.
  • Additional New Items:
    • Accommodation policies, requests and how resolution;
    • Assessment of personnel process; and,
    • Assessment of physical and mental qualifications.
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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.