On September 30, 2014, a notice was published in the Federal Register announcing the Office of Management and Budget (OMB) approval of a revised Scheduling Letter, Itemized Listing, and Compliance Check Letter for the Office of Federal Contract Compliance Programs (OFCCP).
The notice can be found at: http://www.gpo.gov/fdsys/pkg/FR-2014-09-30/pdf/2014-23177.pdf. Copies of the revised Scheduling Letter, Itemized Listing, and Compliance Check Letter can be found at: http://www.reginfo.gov//public/do/PRAViewIC?ref_nbr=201104-1250-001&icID=13735. Click on the files in the “Instrument File” column to view each document.
The most significant change in the Itemized Listing, which was expanded from eleven items to twenty-two, involves the request for compensation data. Contractors will no longer submit aggregate compensation data and instead will submit the data by individual employee, including gender, race/ethnicity, hire date, job title, job group, and EEO-1 category, as of the date of the workforce analysis. The OFCCP has modified their definition of compensation to include hours worked, incentive pay, merit increases, locality pay, and overtime. Contractors will also be required to submit activity data by sex and race/ethnicity using five specific categories, as opposed to minority/nonminority. The race/ethnic categories match the OFCCP regulations and not the categories used to prepare the EEO-1 Reports. Hopefully the OFCCP will permit the same race/ethnic categories used for the EEO-1 Report as the agency now does for AAP components.
The Scheduling Letter has also been modified to incorporate changes due to the revisions made to the Vietnam Era Veterans’ Readjustment Assistance Act of 1974 (VEVRAA). There were no substantial changes to the Compliance Check Letter.
Please contact us by calling (732) 446-2529 or sending us an e-mail at glennbarlett@gbcs.net if you are interested in discussing the revised Scheduling Letter, Itemized Listing, and Compliance Check Letter.