NT Lakis lawyers have filed written comments with the White House Office of Management and Budget (OMB) on two new scheduling letters proposed by the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP). As we have reported previously, the proposed letters are designed to notify federal construction contractors that they have been scheduled for a so-called “compliance check,” a type of abbreviated compliance evaluation ostensibly intended to lessen the burden on both the contractor and the agency.
Under federal Paperwork Reduction Act (PRA) requirements, OFCCP must get approval from OMB before it can begin using the new scheduling letters. In turn, OMB has the authority to order OFCCP to make further revisions to the letters before giving its approval. As discussed in more detail below, the comments recommend that OMB require further changes to the letters before approving them that are more in line with the intended purpose of the compliance check and modeled after the compliance check letter OFCCP currently uses for supply and service contractors.
Members of the Center for Workplace Compliance (CWC) can read more here.