More than three years after the Office of Federal Contract Compliance Programs (“OFCCP”) sought approval for a new Scheduling Letter and Itemized Listing, OFCCP published a notice in the Federal Register on September 30, 2014 revealing that it had received Office of Management and Budget (“OMB”) approval. Yesterday, OFCCP announced that it would not schedule any supply and service compliance evaluations from October 1, 2014 to October 15, 2014 to allow contractors to “become acquainted with the new letter and itemized listing”, but it plans to start using the new Scheduling Letter and Itemized Listing for all audits scheduled after October 15, 2014.
Tag Archives: itemized listing
On October 27, 2011, United Space Alliance, LLC (“USA”), the government’s primary contractor for manned space missions, argued to Judge Royce C. Lamberth, the Chief Judge for the Federal District Court for the District of Columbia, that the Office of Federal Contract Compliance Programs’ (“OFCCP’s”) request for compensation data for periods beyond its initial scheduling letter violated the Administrative Procedures Act (“APA”) and the Fourth Amendment. Continue reading
On September 29, 2011, the Office of Federal Contract Compliance Programs (“OFCCP”) published a Notice that it was submitting a revised scheduling letter and itemized listing to the Office of Management and Budget (“OMB”) for approval. In May of this year, OFCCP sought OMB’s approval and public comment on a proposed new scheduling letter and itemized listing. Continue reading
OFCCP Seeks Additional Contractor Data in Proposed Changes to the Scheduling Letter, Itemized Listing, and Compliance Check Letter
On May 12, 2011, the Office of Federal Contract Compliance Programs (“OFCCP”) announced in the Federal Register that it was seeking approval from the Office of Management and Budget (“OMB”) to revise three forms (i.e., the Scheduling Letter, Itemized Listing, and Compliance Check Letter) it uses to collect data from contractors during compliance reviews. Although OFCCP claimed in a Supporting Statement issued with the proposed revisions that the changes to the forms would “reduce overall burden hours on contractors,” it is clear that these proposed alterations, particular those made to the Itemized Listing, would drastically increase contractors’ administrative burdens associated with recordkeeping and preparation of affirmative action plans. Continue reading