OFCCP Proposes Changes To Audit Scheduling Letters

Quick Hit: OFCCP recently issued a request to the Office of Management and Budget ("OMB") seeking approval of changes to its "scheduling letter, compliance check letter, [] Section 503 focused review letter... [and] approval for a new VEVRAA focused review letter." OFCCP states the revised letters will "provide OFCCP an efficient option to monitor contractor compliance by reaching a greater number of contractors with existing resources with a smaller contractor burden imposed during each check." Each of the proposed compliance letters are available for review here. The public has until June 11, 2019 to submit comments about the proposed changes.

Key Takeaways:

If approved, the new letters will require contractors to submit significant additional information in response to an audit. Notably, the proposed letters do not extend the deadlines for responding to these information requests. These letters reflect a troubling trend emanating from the OFCCP. After an