As we reported previously, the OFCCP submitted final revised scheduling letters for “regular” audits, compliance checks, and Section 503 (disability) focused reviews, along with a new scheduling letter for VEVRAA (veteran) focused reviews, to the White House Office of Management and Budget (OMB) for approval back in July, 2019. Nearly nine months later, OMB has finally approved these new scheduling letters for use.
Most notably, the OFCCP can now begin scheduling veteran focused reviews in earnest. OMB approval is required for any “information collection” the agency uses for more than 10 people. The FY 2019 Corporate Scheduling Announcement List (CSAL) contains 500 contractor establishments or functions selected but not yet scheduled for review.
The OFCCP solicited public comment on their originally proposed revised and new scheduling letters, and the federal contracting community responded energetically to several proposed changes such as:
- Submitting actual copies of compensation analyses;
- Calculating availability and setting placement goals by specific race/ethnicity categories;
- Submission of promotion “pools;” and
- Several other changes viewed by contractors as overly burdensome and overreaching.
The agency backed off most of the more controversial changes and submitted revised documents to the OMB for final approval. Those revised documents are the ones that have now been approved for use.
BCGi will follow up with more detail and analysis of the revised and new scheduling letters in the near future. In the meantime, the documents themselves are available online for download here.