Share on LinkedInShare on LinkedIn

ARTICLE · 08 MAY 2023

OFCCP Proposes Revised Scheduling Letter And Itemized Listing

Proskauer Rose LLP
Proskauer Rose LLP
Contributor
Proskauer Rose LLP

Proskauer Rose LLP

Firm Overview Proskauer is an elite global law firm with more than 900 lawyers across key financial...

View firm profile
Explore more from Proskauer Rose LLP

As we previously reported, OFCCP is seeking reauthorization of a revised Compliance Review Scheduling Letter ("Scheduling Letter") and Itemized Listing. The Scheduling Letter and Itemized...

United StatesGovernment, Public Sector
Guy Brenner
Guy Brenner
Olympia Karageorgiou
Olympia Karageorgiou
Author LinkedIn connections

As we previously reported, OFCCP is seeking reauthorization of a revised Compliance Review Scheduling Letter ("Scheduling Letter") and Itemized Listing. The Scheduling Letter and Itemized are issued by OFCCP at the outset of an audit and request multiple categories of documents from federal contractors selected for audit. A detailed discussion of the originally proposed changes are available here.

After giving the public an opportunity to comment on the proposed changes, on April 17, 2023, the Office of Management and Budget (OMB) published a revised version of the proposed Scheduling Letter and Itemized Listing.

OFCCP's only substantive proposed revision to the Scheduling Letter is to allow contractors to submit their responses through the Contractor Portal, in addition to the existing email, electronic submission, and physical mail options.

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

See more popular content from

Article

SBA Extends Deadline For Comments On Historic Overhaul Of Size Standards

The Small Business Administration has extended the comment period for two proposed rules that could dramatically reshape federal government contracting by significantly expanding the pool of entities eligible for small business set-aside procurements. With some size standard thresholds proposed to increase as much as tenfold, these changes would fundamentally alter the makeup of the small business contractor base.
United StatesGovernment, Public Sector
Crowell & Moring LLP
Crowell & Moring LLP
Article

BIOSECURE Act Update: Court Enjoins WuXi AppTec’s 1260H Designation, but Strategic and Compliance Clocks Keep Running

The U.S. District Court for the District of Columbia has preliminarily enjoined the Department of War from enforcing WuXi AppTec's Section 1260H designation, finding the agency misread its evidence on state and military affiliation. However, this ruling does not close alternative pathways to biotechnology company of concern (BCC) designation under the BIOSECURE Act, and earlier supply-chain restrictions continue to drive near-term compliance decisions with a critical June 30, 2027 deadline for sub-tier supp
United StatesGovernment, Public Sector
Greenberg Traurig
Greenberg Traurig
Article

Massachusetts’ 2026 Ballot Questions: What Clients Need To Know

Massachusetts voters will decide nine statewide ballot questions in November 2026 that could fundamentally reshape the state's legal, regulatory, and fiscal landscape. These measures address government transparency, election reforms, housing development, marijuana regulation, firearms laws, and state revenue limits, with implications extending far beyond Election Day to implementation, regulation, and ongoing policy debates.
United StatesGovernment, Public Sector
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Mintz, Levin, Cohn, Ferris, Glovsky and Popeo, P.C.
Article

Weekly Sanctions Update: September 14, 2026

The Treasury Department intensifies economic pressure on Iran through Operation Economic Outcast, suspending aviation licenses and sanctioning dozens of entities while implementing a presumption of denial for Iran-related transactions. Meanwhile, new enforcement actions target Chinese cybercrime platforms, Ecuadorian terrorist organizations, and Israeli settlers, as Congress considers comprehensive Russia-Iran sanctions legislation.
GlobalGovernment, Public Sector
Steptoe LLP
Steptoe LLP
Article

DOJ Continues DEI False Claims Act Enforcement With $25 Million Accenture Settlement

The Department of Justice announced a $25 million settlement with Accenture Federal Services over allegations that the company violated the False Claims Act by falsely certifying compliance with anti-discrimination requirements while allegedly using race or sex in hiring, promotion, and access to professional development programs. This marks the third major DEI-related FCA enforcement action in 2026, following similar settlements with IBM and Deloitte.
United StatesGovernment, Public Sector
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

Weekly Sanctions Update: September 21, 2026

The Lindsey O. Graham Sanctioning Russia and Iran Act of 2026 has become law, imposing sweeping sanctions on Russian officials, financial institutions, and shadow fleet vessels while authorizing tariffs up to 100 percent on major purchasers of Russian oil and natural gas. How will these new measures impact global trade relationships, particularly with China and India as the largest buyers of Russian crude?
GlobalGovernment, Public Sector
Steptoe LLP
Steptoe LLP
Article

DOJ's $2 Million Honeywell Settlement Under The Civil Cyber-Fraud Initiative: What Compliance Failures Mean For Defense Contractors

The Department of Justice secured a $2 million settlement with Honeywell Aerospace for allegedly failing to comply with NIST SP 800-171 cybersecurity requirements under a Department of War contract. This case demonstrates how cybersecurity compliance failures can trigger False Claims Act liability even without an actual data breach or cyberattack, and highlights the growing role of whistleblowers in exposing contractors' gaps between contractual obligations and actual security practices.
United StatesGovernment, Public Sector
Bass, Berry & Sims PLC
Bass, Berry & Sims PLC
Article

National Historic Preservation Act Overhaul: What You Need To Know

The Advisory Council on Historic Preservation has advanced a Notice of Proposed Rulemaking that would fundamentally restructure Section 106 of the National Historic Preservation Act, marking the most significant regulatory overhaul in over 20 years. The proposed changes would shift the consultation process from a multi-step framework to an agency-prepared report system, narrow the scope of protected properties, and grant federal agencies greater unilateral authority in resolving adverse effects.
United StatesGovernment, Public Sector
Kelley Drye & Warren LLP
Kelley Drye & Warren LLP
Article

SEC Advances “Responsible Retailization” Through A Potential Accredited Investor Exam And Potential Regulated Fund Reforms

On September 30, 2026, the Securities and Exchange Commission (SEC) issued two rule proposals and five notices aimed at expanding investors’ access to private markets. The package would add ways to qualify as an accredited investor, including passing a new exam administered by the Financial Industry Regulatory Authority (FINRA), broaden performance-based compensation and modernize regulated funds, including interval funds and business development companies (BDCs).
United StatesFinance and Banking
Proskauer Rose LLP
Proskauer Rose LLP
Article

DOL Pulls The Plug On Plan To Move FLSA Interpretations Out Of The CFR

The U.S. Department of Labor's Wage and Hour Division has withdrawn its controversial proposal to remove nine parts of longstanding Fair Labor Standards Act interpretive guidance from the Code of Federal Regulations. What does this reversal mean for employers who have relied on these decades-old interpretations, and how does the Supreme Court's Loper Bright decision reshape the legal weight of agency guidance going forward?
United StatesEmployment and HR
Proskauer Rose LLP
Proskauer Rose LLP
Article

Parliament’s Position On SFDR 2.0

The European Parliament's Committee on Economic and Monetary Affairs has adopted its position on the Sustainable Finance Disclosure Regulation reform, establishing key divergences with the European Commission and Council on professional investor exemptions and fossil fuel investment criteria. With trilogue negotiations set to begin in October 2026, private markets managers face critical decisions about how to position their funds under the new three-category framework expected to take effect in early 2029.
United KingdomCorporate/Commercial Law
Proskauer Rose LLP
Proskauer Rose LLP
Article

False Claims Act Roundup Series: Q2 2026 – Federal And State Agencies Use Data To Operationalize Enforcement

The Department of Justice has operationalized its fraud-enforcement architecture through data analytics, targeting healthcare providers with multi-district strike forces, Medicare Advantage risk-adjustment actions, and accelerated qui tam review processes. How are federal and state agencies using publicly available data to drive False Claims Act enforcement, and what proactive steps should healthcare organizations take to identify and remediate potential exposure before becoming the focus of government atte
United StatesFood, Drugs, Healthcare, Life Sciences
Proskauer Rose LLP
Proskauer Rose LLP
Article

Separate Confidentiality Agreement Rendered Arbitration Agreement Unconscionable

A California Court of Appeal examined whether an arbitration agreement signed during employee onboarding was enforceable when paired with a confidentiality agreement that created a one-sided dispute resolution structure. The court analyzed both procedural and substantive unconscionability, focusing on how the combined documents favored the employer's ability to litigate certain claims while forcing the employee into arbitration for wage-and-hour disputes.
United StatesLitigation, Mediation & Arbitration
Proskauer Rose LLP
Proskauer Rose LLP