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:
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 14.
Questions? Email Kellie Nurko or call (973) 848-4752