Meet OFCCP's New Scheduling Letters, Same As The Old Scheduling Letters?

As faithful readers of this blog know, OFCCP proposed significant changes to its audit scheduling letters in April 2019, and then scaled back those changes in June 2019 revisions. Now, close to a year after OFCCP commenced the process, the Office of Management and Budget ("OMB") has approved revised scheduling letters – specifically, scheduling letters for compliance evaluations, compliance checks, and Section 503 and VEVRAA focused reviews.

But, what changes did OMB ultimately approve and what do those changes mean for contractors? It turns out OMB approved very few changes to the scheduling letters. In fact, the most notable feature of the new scheduling letters are the provisions OMB rejected.