On September 30, 2014, the Federal Registry released a notice stating the Office of Management and Budget’s (OMB) approval of the revised Scheduling Letter. The scheduling letter will include minor changes such as correction of legal citations and the change of language used to better reflect the regulatory structure of compliance evaluations.
The major changes of the scheduling letter to note include:
- The OMB rejected the proposal of requiring contractors to submit employment transactions data by job group AND job title, instead it will revert to the 2008 Itemized Listing, allowing contractors to continue submitting their employment transactions data by either job group OR job title.
- The submission of the employment transactions data will be by gender and individual race and ethnicity (five specified categories) instead of total minority and nonminority.
- Instead of submitting annualized aggregate compensation data, contractors will submit employee level compensation data as of the date of the workforce analysis in their Affirmative Action Plan by job title, job group, and EEO-1 category.
- The OFCCP encouraged the use of electronic submission of data in the 2008 scheduling letter, however, in the revised letter, contractors are required to submit their data electronically, given that it is maintain in an electronic format.
Stay tuned for more information as the OFCCP has not release the finalized revised Scheduling Letter.