OFCCP Director Patricia Shiu, stated "the old regulations were simply not cutting it". Directors Shiu added that the new NPRM "is going to be a game changer" for federal contractors. Pushing the Limits
Contractors is finding themselves producing additional compensation data to OFCCP even if the "threshold tests conducted by OFCCP during the desk audit do not produce indicators of discrimination. Cases like the one with United Space Alliance have emboldened the OFCCP even further. New Wave of OFCCP Scheduling Letters Coming Soon Be ready for the new Scheduling Letter - and make sure you have the resources available.
The proposed revision to the OFCCP's Scheduling Letter should put contractors on notice that OFCCP is playing for keeps. The new Scheduling Letter and Itemized Listing require contractors to produce detailed personnel records at the start of the desk audit phase and not when contractors have indicators of discrimination.
Changes to the Scheduling letter will impact the labor intensity of recordkeeping efforts of contractors, meaning that contractors must be more diligent in their recordkeeping efforts and in conducting self-audits. A few of the changes are listed below:
Have your policies ready, OFCCP will be requiring contractors to submit policies concerning employment leave, this will cover accommodations for religious observances, pregnancy leave and medical leave; however, the agency's request will not be limited to just these.
Detailed records for applicants, hires, promotions and terminations by job title and job group had broken down by gender and race. Contractors will also be required to provide the pool of candidates considered for terminations and promotions.
Moving forward contractors should work closely with their consultant to ensure that they are clearly understand the new regulations as they apply to their affirmative action plan requirements, recordkeeping and document retention? The current changes will impact hiring managers and recruiters as well, ensure that they are brought up to speed on their affirmative action plan responsibilities.
Founded in 1979, Career Resources is a privately owned company which develops Affirmative Action and Diversity Plans, provides Diversity and Affirmative Action Plan implementation, online e-Learning courses, Sexual Harassment Training, EEOC and OFCCP vulnerability audits, OFCCP audit support used by hundreds of organizations nationwide including fortune 500 companies and small/medium size businesses in all industries.