News and Information

OFCCP Proposes Significant Changes to Compliance Audit Scheduling

OFCCP Proposes Significant Changes to Compliance Audit Scheduling On November 21, 2022, the Office of Federal Contract Compliance Programs (OFCCP) published a notice in the Federal Register seeking to revise its Compliance Review Scheduling Letter and Itemized Listing, which are sent upon the initiation of an OFCCP audit. Proposed changes include:

• Scheduling letter: Contractors with a “campus-like setting” maintaining multiple AAPs would be required to submit information for all AAPs in the same city and state
• Itemized listing: A general statement in the contractor’s AAP narrative that they have conducted an in-depth review of all personnel processes would no longer suffice. Detailed documentation of compliance efforts covered by Executive Order 11246, Section 503, VEVRAA, and the Request for Personal Activity Data (promotions, terminations and compensation) would be required.

In addition, if the contractor is 6 months or more into their current AAP year when the scheduling letter is received, they would also be required to provide updated information for selected categories at least the first half of the current year. 

The OFCCP estimates that the additional requested information will require an average of 39 hours of extra work per establishment for each response. 

Public comments on the proposed revisions will be accepted through January 20, 2023. See the notice here.