This is the third of our series of blog posts on the Office of Management and Budget’s (OMB) July 1 request for comments on OFCCP’s updated proposed scheduling letters. For background, OFCCP first proposed changes to its existing compliance check, establishment review, and focused review scheduling letters in April, and received comments from
Regulatory Update
Data System Security Info and File Specifications Added to EEO-1 Pay Data Reporting Website
As July 15th draws closer, EEOC and NORC are ramping up for opening of the EEO-1 Component 2 Pay Data reporting portal.
As part of these efforts, they are consistently providing new information on the reporting obligation. Most recently, the reporting website has been updated to include assurances from NORC on data system security…
What’s New with the Updated Proposed Compliance Check Scheduling Letter?
In April, OFCCP proposed four new scheduling letters – one each for its establishment reviews, compliance checks, and separate but related letters for its focused reviews on Section 503 (disability) and VEVRAA (veteran) compliance. These proposed letters, if approved, would have significantly increased the burden of the submission required in the event of…
Additional Insights on the New Updated EEO-1 Component 2 Pay Data Materials
As we previously reported, on July 2, EEOC updated the its newly created website with long-awaited materials regarding the obligation of employers with 100 or more employees to submit pay data and hours worked data as part of the annual EEO-1 reporting obligations.
We anticipated EEOC would not change much relative to the materials…
OMB Seeks Public Comment on OFCCP’s Revised Scheduling Letters
On Friday, the Office of Management and Budget (OMB) published notice it would begin reviewing the proposed changes to OFCCP’s Supply and Service scheduling letters, including the Section 503 and VEVRAA Focused Reviews and Compliance Check letters. OMB is seeking public comments until July 29, 2019 to aid in its review. Under the Paperwork Reduction…
EEOC On Schedule to Open Component 2 Reporting July 15, 2019
In its most recent status update, filed with the court as ordered by Judge Tanya S. Chutkan, EEOC is reporting it and NORC are on schedule to open the EEO-1 Component 2 pay data reporting tool on July 15, 2019.
The status report explained that a Computer-assisted Web Interview (CAWI) data collection instrument will be available on July 15, 2019. Importantly, the report noted that NORC is working on a data file upload function and validation process which is expected to be available as an additional data collection method no later than August 15, 2019.Continue Reading EEOC On Schedule to Open Component 2 Reporting July 15, 2019
EEOC on Target to Open Pay Data Collection Portal In July
In its latest progress report, submitted to the Court on May 24, 2019, the EEOC details its efforts over the past weeks to get the new EEO-1 pay data reporting tool up and running.
The report details meetings between EEOC and NORC to develop training materials and a Help Desk to field questions from…
OFCCP Adds to 2019 Rulemaking Agenda
This week the Department of Labor announced its spring 2019 Regulatory Agenda. Included was an new item from OFCCP that was part of its prior published regulatory agenda. As OFCCP previously announced in 2018, its planned rule-making agenda for the near future includes rulemaking to address affirmative action obligations for TRICARE providers (slated for May 2019) and contractor’s use of religious exemptions (slated for June 2019).
Continue Reading OFCCP Adds to 2019 Rulemaking Agenda
Director Leen Shares OFCCP Update
OFCCP Director Craig Leen thinks the Agency has made good progress on implementing “the four pillars” but there is still work to be done.
Speaking this week in Florida, Director Leen shared accomplishments, and things to come, for each of the four tenants. However, he noted he was not allowed to comment on the pending proposed changes to the scheduling letters.Continue Reading Director Leen Shares OFCCP Update
OFCCP Proposes Construction Compliance Check Letters
In furtherance of its work as an enforcement agency and its commitment to conduct reviews of more contractors, OFCCP posted in the Federal Register on Monday, April 8, 2019 its proposal for a series of compliance check audit letters for construction contractors. The agency is request feedback on two proposed construction compliance check letters – …