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Category: Compliance Reporting and Recordkeeping

Template for Assessing Disability and Veteran Outreach

The Center for Workplace Compliance (CWC), our affiliated nonprofit membership association, has updated its template for assessing outreach to persons with disabilities and protected veterans. It can assist CWC’s federal contractor members in organizing their data so they’re ready if the Office of Federal Contract Compliance Programs (OFCCP) audits them. The template also should make it easier to respond to items...
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Category: Compliance Reporting and Recordkeeping

Responding to Item 21 on the OFCCP Scheduling Letter’s Itemized Listing

In the year since the Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) began using a more burdensome Scheduling Letter and Itemized Listing to notify federal contractors of an upcoming compliance evaluation, Item 21 on the Itemized Listing has generated confusion. Item 21 asks the contractor to identify and document “policies, practices, or systems used to recruit, screen, and...
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Category: Compliance Reporting and Recordkeeping

CWC Comments to OMB Argue Against Reinstatement of OFCCP’s Burdensome Form CC-257

CWC has submitted written comments to the White House Office of Management and Budget (OMB) contending that the Office of Federal Contract Compliance Programs’ (OFCCP) request to reinstate the Monthly Employment Utilization Report (Form CC-257) is unnecessary and burdensome. The form would require covered construction contractors and subcontractors to collect and report headcount and hours-worked data by race, ethnicity, sex,...
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Category: Compliance Reporting and Recordkeeping

2024 VETS-4212 Filing Season Underway, Submission Deadline Is September 30

The Labor Department’s Veterans’ Employment and Training Service (DOL-VETS) has opened the filing system for the VETS-4212 Report. The submission deadline is September 30, 2024. The VETS-4212 form provides a workforce snapshot by protected veteran status, as well as the number of protected veteran new hires for the preceding 12-month period. Federal contractors and subcontractors are required to file it...
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Category: Compliance Tools

CWC’s Updated Template for Mandatory ESDS Notifications Under VEVRAA

CWC has updated a template that can assist its federal contractor members in meeting their employment service delivery system (ESDS) notice requirements. CWC’s members can use the updated template to satisfy the Office of Federal Contract Compliance Programs’ (OFCCP) ESDS notice obligations under the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) requirements codified at 41 CFR § 60-300.5(a)(4). That rule...
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Category: Compliance Reporting and Recordkeeping

FAR Council Proposes Reinstating Lapsed Contractor Reporting Requirement

The Federal Acquisition Regulatory (FAR) Council wants to reinstate a requirement obligating covered federal contractors to report executive compensation and first-tier subcontract awards. The FAR Council is an interagency entity that coordinates federal government procurement policy and regulatory activities. In a notice published May 24, 2024, the FAR Council indicated that it will seek approval from the White House Office of...
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Category: Agency Enforcement

OMB Approves OFCCP’s Burdensome New Construction Contractor Scheduling Letter

The White House Office of Management and Budget (OMB) has approved the Office of Federal Contract Compliance Programs’ (OFCCP) expanded version of the Scheduling Letter and Itemized Listing for notifying construction contractors of a compliance evaluation. OMB also has approved a revised version of OFCCP’s new Construction Contract Award Notification Requirement Form (Form CC-314). Both approvals begin July 31, 2024,...
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Category: Affirmative Action and Diversity

CWC Urges OMB To Ameliorate Burden Imposed by OFCCP’s Construction Contractor Letter

The Center for Workplace Compliance (CWC) has submitted comments to the White House Office of Management and Budget (OMB) in response to a request from the Office of Federal Contract Compliance Programs (OFCCP) for authorization to use an expanded version of the construction contractor scheduling letter and itemized listing that the agency uses to notify construction contractors of a compliance...
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Category: Compliance Reporting and Recordkeeping

OFCCP Submits Formal Request to OMB To Reinstate Burdensome Construction Contractor Report

The Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) has submitted a formal request to the White House Office of Management and Budget (OMB) to reinstate the burdensome Utilization Report (Form CC-257). The report will require covered construction contractors and subcontractors to collect and report headcount and work hours data by race, ethnicity, sex, and construction trade on a...
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Category: Agency Enforcement

OFCCP Asks OMB To Expand Construction Scheduling Letter and Itemized Listing

The Labor Department’s Office of Federal Contract Compliance Programs (OFCCP) has submitted a formal request to the White House Office of Management and Budget (OMB) to use a more detailed scheduling letter and itemized listing to notify federal construction contractors of a compliance audit. OFCCP unveiled its proposal for a new scheduling letter back in March. The Center for Workplace Compliance (CWC), our...

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