NT Lakis, on behalf of the Center for Workplace Compliance (CWC) has filed written comments with the White House Office of Management and Budget (OMB) in response to the proposal submitted by the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) to implement an online portal through which federal contractors would be required to: (1) certify annually that they have developed and maintained Affirmative Action Programs (AAPs) in accordance with OFCCP’s regulations; and (2) upload and submit their written AAPs in response to notice of a compliance evaluation.
Under federal Paperwork Reduction Act (PRA) requirements, OFCCP must get approval from OMB before it can begin requiring contractors to use the portal to certify their compliance. In turn, OMB has the authority to order OFCCP to make further revisions before giving its approval.
Our comments recommend that OMB consider and instruct OFCCP to implement an equally effective but less burdensome alternative – an alternative supported overwhelmingly by numerous other organizations in comments filed with OFCCP – that the certification requirement occur every two years, rather than annually.
Members of the Center for Workplace Compliance (CWC) can read more here.