OFCCP Proposes Major Changes to Audit Requirements

May, 2011

Earlier this month, the Office of Federal Contract and Compliance Programs (OFCCP) published another proposed rulemaking regarding its Scheduling Letter and Itemized Listing.

The Scheduling Letter is used to notify covered contractors that they’ve been selected for an audit, and the Itemized Listing requires employers to submit a variety of information including its Affirmative Action Plan, personnel flow (applicant flow, hires, terminations and promotions) and compensation data.

The OFCCP’s proposed rules greatly expand the amount and detail of information covered contractors will need to provide. Highlights of the proposed rules include new requests for: policies on various types of protected leave and accommodations, personnel flow data provided by job group, job title and broken down by race and ethnicity, compensation data as it is on February 1 (no exceptions), separate breakdown of compensation data including all items included in compensation (base pay, commissions, bonuses, etc.), all variables that affect pay (education, length of service, performance, etc.) and any documentation or policies that affect pay.

The net result of the proposed changes means a much greater burden on employers in developing and maintaining their affirmative action programs. If you need assistance with your program, please contact Cascade.


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