The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, wrote a comment letter to the Labor Department’s Office of Federal Contract Compliance Programs urging OFCCP to abandon expansive changes it is proposing to the Scheduling Letter through which it notifies federal construction contractors of an upcoming compliance evaluation. OFCCP solicited public comments on its proposed changes, as required by the federal Paperwork Reduction Act.
CWC expressed particular concern regarding proposed new Items 3, 16, and 17 of the Itemized Listing that accompanies the Scheduling Letter. These changes would require contractors to provide, at a review’s desk audit stage, additional payroll and employment activity data, evidence that tests and selection procedures were validated, and evidence that personnel and employment-related activities were monitored for discriminatory effects. CWC argued that it would be better to limit detailed information requests to cases where there is a potential problem. CWC also believes that OFCCP is vastly underestimating the burden that its revised Scheduling Letter and Itemized Listing would impose on construction contractors.
CWC members can read more here.