OFCCP's New Revised Audit Letter and Attached Itemized Listing Requires Contractor Attention Now
The Office of Federal Contract Compliance Programs (OFCCP) is poised to release a new version of its audit scheduling letter and Itemized Listing soon. The new Itemized Listing contains significant changes compared to the current version. Among those changes are:
- Requiring the submission of hires, applicant, promotions, and terminations data by job title in addition to affirmative action plan job group
- Requiring the submission of detailed line item employee-by-employee compensation data, including compensation data related to overtime, commissions, bonuses, incentives, locality pay, merit increases, and hours worked
- Requiring employers to maintain and track promotion pools and termination pools (in RIF decisions), and submit that information
- Requiring unionized companies to produce in the initial audit response all policy statements, employee notices or handbooks that "implement, explain or elaborate on the collective bargaining agreement"
- Requiring the submission of policies on compensation, leaves, and accommodations
- Requiring the submission of documents related to accommodations granted
OFCCP also indicated in its September 28 response to the submitted comments that government contractors and subcontractors are required to include temporary employees in their affirmative action plans and in pay data sought under the new audit letter, and that "contract, per diem, or day laborers" are categories of temporary employees.
It is important that government contractors and subcontractors understand fully what the new Itemized Listing will require companies to produce within 30 days of receiving an audit notice. Despite OFCCP's insistence that "the amount of time needed by contractors or their human resource providers/vendors to modify data tracking and data analyses is not excessive," and that all that is needed is "the development or modification of a database query," we believe it is going to take substantial efforts for some companies to get ready.
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This webinar is also being offered on December 12.
Questions? Email Kellie Nurko or call (973) 848-4752