NT Lakis lawyers filed written comments with the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) this week on the agency’s proposed changes to the various letters it uses for scheduling most federal contractors for standard compliance audits under the laws OFCCP enforces.

Ostensibly proposed in the name of efficiency, OFCCP’s proposed changes are in fact extensive, and would increase substantially the administrative burden imposed on federal contractors at the outset of a routine compliance evaluation.

Indeed, our comments challenge a basic but flawed premise upon which OFCCP apparently relies in proposing the changes – that in order to effectively carry out its enforcement responsibilities, the agency must have access at the outset of every compliance evaluation to virtually any employment data that might become relevant in case a compliance issue later surfaces during the audit.

We urge OFCCP to abandon or scale back many of its proposed changes that we contend will add to the burden on contractors during the desk audit phase of an audit, and instead reserve its right to demand additional information from a contractor only when its investigation so warrants.

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