Thursday, October 2, 2014

OFCCP COMPLIANCE CHECKS ARE BACK

The Department of Labor's Office of Federal Contract Compliance (OFCCP) announced this week that the Office of Management and Budgeting (OMB) had approved the revised scheduling letter and itemized listing. We all already know this, right?

In that same news release, however, is a brief mention of a "compliance check" and contains a link to the Compliance Check Letter. Compliance Checks were one tool that OFCCP used in years past to conduct brief compliance assessments as well as a means of identifying federal contractors for full compliance evaluations based on those assessments.

For those of you not familiar with the Compliance Checks of years past, here is how the process works. OFCCP sends you a letter and requests the three items listed below. The letter says that you will receive a call from an OFCCP Compliance Officer (CO) to schedule an on-site so that the CO can inspect these three items. The new Compliance Check procedures now allow an alternative to the on-site and permits the company to submit the items by USPS or email within the 30 days.
  • Your AAP results for the preceding year (41 CFR § 60-1.12(b)).
  • Examples of job advertisements, including listings with state employment services (41 CFR § 60-1.12(a), § 60-300.80, and § 60-741.80).
  • Examples of accommodations made for persons with disabilities (41 CFR § 60-1.12(a), § 60-300.80, and § 60-741.80).
We will keep you posted as we hear more about OFCCP's approach in implementing the new Compliance Checks.

Wednesday, October 1, 2014

OFCCP SCHEDULING LETTER UPDATE

As we indicated in our Kairos News Feed of September 30, 2014, the much anticipated new OFCCP Compliance Evaluation Scheduling Letter, along with the Itemized Listing, was approved by OMB on September 30, 2014. Yesterday, the OFCCP announced that the Letter and Listing became effective October 1, 2014. However, OFCCP went on to say that it will not schedule supply and service compliance evaluations between October 1 through October 15, 2014 so that contractors can use this period to review and become acquainted with the new letter and itemized listing. See link below for accessing the Compliance Evaluation Scheduling Letter.