20-Minute Webinar: What You Need To Know About the OFCCP Scheduling Letter Revisions
This webinar was originally presented on November 3, 2014.
On September 30, 2014, the OFCCP announced that OMB approved the agency’s revised compliance evaluation Scheduling Letter and Itemized Listing, and the Compliance Check Letter covering the Executive Order 11246 supply and service contractor compliance evaluations. The new Scheduling Letter is effective October 16, 2014.
- Incorporates certain changes due to new VEVRAA regulations (effective March 24, 2014).
- States that OFCCP will verify VETS-100A (VETS-4212) reporting compliance.
- “Encourages” the contractor to submit its data electronically.
- Contractors still allowed to submit employment activity data by either job group or job title.
- Contractors must now submit race and ethnicity information using five specified categories (African-American/Black, Asian/Pacific Islander, Hispanic, American Indian/Alaskan Native, White). The “two or more” category is missing from the list. We expect to see guidance on that shortly.
- Contractors must now submit individualized employee compensation data as of date of AAP workforce analysis (also noting job title, job group and EEO-1 category), not annualized aggregate data.
- Contractors required to provide data electronically but only if they maintain it in useable and readable electronic format (compare with “encouragement” in the Scheduling Letter itself).
- Two new sections added to address the VEVRAA and Section 503 requirements required by the March 24, 2014 regulations.
Compliance Check Letter: No substantive changes.