OFCCP Undaunted by Challenges to Scheduling Letter Changes

Constangy, Brooks, Smith & Prophete, LLP
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The Office of Management and Budget announced last week that the Offi ce of Federal Contract Compliance Programs had submitted its proposed changes to the Scheduling Letter and accompanying Itemized Listing to it for approval. The OMB is seeking comments on the OFCCP’s request.

As we reported in May, the OFCCP proposed signifi cant changes to the information that contractors are required to submit when the Agency initiates a desk audit. Comments were accepted until July 11, and many commenters expressed serious concerns about the scope of the information sought and the increased burden associated with responding to the new requests.

Despite these challenges to the OFCCP’s proposal, the Agency has submitted its proposed changes to the Scheduling Letter and Itemized Listing virtually unchanged. The OFCCP dismissed most of the concerns raised and continues to maintain that the amount of time contractors will need to respond will actually decrease, while accepting those comments that supported the proposed changes.

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