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OFCCP Submits Proposed Changes to Scheduling Letters to OMB


OFCCP listens to contractors comments and takes out many proposed revisions to the newer version submitted to OMB

In April OFCCP proposed changes to the Supply & Services scheduling letters and itemized listing (see OutSolve blog). Public comments to the proposed changes were open for submission by June 11, 2019. It is clear that OFCCP listened to comments based on the revised proposed changes submitted to OMB last week.

The following original proposed changes were removed from the scheduling letter and itemized listing that was sent for final approval.

• The need to designate terminations as either voluntary or involuntary.

• The request for the “pool of candidates” for promotions but instead requires the contractor to produce “the workforce representation of women and minorities in the job group from which the person(s) was promoted.”

• The requirement for contractors within more than six months into their current AAP year to provide year-to-date data for “every completed month of the year” but instead retains the existing language requiring the submission for “at least the first six months” of the current year.

• No longer requires the submission of the contractor’s compensation analysis.

• Eliminates the request that contractors provide the specific racial categories of employees in the job group analysis, availability analysis, setting of placement goals, and prior year goal progress. Additionally, the contractor will not be required to set goals for individual racial groups or for racial groups of a specific sex.

• Instead of requiring contractors to identify their “three largest subcontractors based on contract value” they will be required to identify “three most recently awarded subcontracts that have a total contract value of $150,000 or more.”

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