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ARTICLE · 22 AUGUST 2011

OFCCP Takes Initial Steps To Require Burdensome Reporting Of Compensation Data

Morgan Lewis
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In an Advanced Notice of Proposed Rulemaking (ANPRM) published in the Federal Register on August 10, the Office of Federal Contract Compliance Programs (OFCCP) solicits public comments on a proposed requirement that contractors submit extensive compensation data to the agency through a webbased collection tool.

United StatesEmployment and HR
Morgan, Lewis & Bockius LLP'S Labor & Employment Practice
Morgan, Lewis & Bockius LLP'S Labor & Employment Practice

In an Advanced Notice of Proposed Rulemaking (ANPRM) published in the Federal Register on August 10, the Office of Federal Contract Compliance Programs (OFCCP) solicits public comments on a proposed requirement that contractors submit extensive compensation data to the agency through a webbased collection tool. The proposed reporting requirement would impose substantial new burdens on contractors at a time when the OFCCP has many other proposals pending that will also considerably increase the compliance burden.1 For example, OFCCP has proposed revisions to the scheduling letter to request more detailed pay and personnel data in every audit.

The ANPRM explains that the data collection tool under consideration will be used in part by OFCCP to select contractors for intensive compensation audits. The OFCCP requests comments on the following types of issues:

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