On November 17, 2014, the Office of Federal Contract Compliance Programs (OFCCP) posted a new Frequently Asked Questions (FAQs) page clarifying Item 19, the expanded compensation data request, of the revised Itemized Listing attached to the new Compliance Review Scheduling Letter, approved by the Office of Management and Budget (OMB) on September 30, 2014. The Item 19 FAQs can be found at: http://www.dol.gov/ofccp/regs/compliance/faqs/SchedulingLetter_FAQs.html. The new FAQs can also be found by navigating to the OFCCP homepage found at: http://www.dol.gov/ofccp/, clicking on ‘Compensation Guidance’ in the ‘Other Resources’ section of the ‘Federal Contractor Corner’ box found on the right side of the page, and then clicking on ‘FAQs on Scheduling Letter Itemized Listing Item 19 Compensation Data’.
The OFCCP has confirmed that contractors may provide support data by the seven race/ethnicity groups used for the EEO-1 Report as previously allowed in Directive 2008-02, which can be found at: http://www.dol.gov/ofccp/regs/compliance/directives/dir283.pdf. The OFCCP has also addressed the time-frame for other compensation or adjustments to salary, stating, “Under the revised scheduling letter, as reauthorized by OMB in September 2014, the snapshot date is the date of the workforce analysis/organizational display. Therefore, for each employee in the workforce analysis/organizational display contractors should provide the actual amount paid in other compensation or adjustments to salary during the 12–month period preceding the date of the analysis/display.” With this set of FAQs, the OFCCP has addressed many of the questions regarding Item 19 of the Itemized Listing. These FAQs, however, do not provide clarification on any other items in the Itemized Listing, with the exception of the use of seven race/ethnicity categories in support data.
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 FAQs.