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.