NT Lakis lawyers have submitted written comments to the White House Office of Management and Budget (OMB) urging the agency to instruct the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) to make needed clarifications to the various information collections associated with OFCCP’s revised Section 503 disability and Section 4212 veterans regulations as a condition of granting OFCCP’s request for OMB approval to extend the requirements for another three years.
OFCCP’s 503/4212 information collection requirements, which include the agency’s prescribed disability self-identification form (Form CC-305), are subject to periodic OMB approval pursuant to the federal Paperwork Reduction Act (PRA). OFCCP submitted a formal request to OMB for extension on December 19, 2016. Although the current approval is set to expire on January 31, 2017, it will be automatically extended on a month-by-month basis while OMB reviews OFCCP’s request.
Our recommendations to OMB, which reiterate the recommendations that we submitted earlier to OFCCP — and which that agency chose to ignore — ask for relatively simple clarifications that we believe will reduce part of the burden imposed on federal contractors while facilitating compliance.
Members of the Equal Employment Advisory Council (EEAC) can read more here.