The Center for Workplace Compliance (CWC) has filed comments with the White House Office of Management and Budget (OMB) urging OMB to reject burdensome changes that the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) has proposed to its compliance audit scheduling letter and accompanying itemized listing. OFCCP’s revised scheduling letter would require covered federal contractors to submit a second employee-level compensation data snapshot for staffing agency employees, along with a new Item 22 on the itemized listing that would require documentation showing that the contractor has satisfied the obligation to evaluate its compensation system(s) for gender-, race-, or ethnicity-based disparities. CWC’s comments focus on areas where CWC believes that OFCCP attempted to make substantive changes to its regulatory requirements without going through mandatory notice and comment rulemaking. The comments also challenge OFCCP’s burden calculations.

Members of the Center for Workplace Compliance (CWC) can read more here.