The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has filed written comments with the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) urging it to reduce the compliance burden posed by its contractor portal. CWC’s comments responded to the agency’s announced intent to seek approval from the White House Office of Management and Budget (OMB) to continue using the portal and require users to enter the Unique Entity ID (UEI) for their parent company and each of the company’s establishments. The portal is an online tool through which covered federal contractors and subcontractors annually certify their development and maintenance of affirmative action plans (AAPs). CWC’s comments caution that UEIs are not an efficient method for identifying unique contracting entities, recalling that EEOC had to quickly modify its EEO-1 online filing system to permit federal contractors to enter UNAVAILABLE for the UEI in cases where no UEI existed or the contractor was unsure which UEI to choose. CWC’s comments also question the agency’s burden estimates and recommend revisions that would make the portal less burdensome.
CWC members can read more here.