The U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) recently posted thirteen new Frequently Asked Questions (FAQs) titled, Scheduling Letter Itemized Listing Item 19 Compensation Data. The questions shed more light on the agency’s newly revamped Compliance Review Scheduling Letter, approved by the Office of Management and Budget (OMB) on October 1, 2014. MALY’s September 30, 2014 Compliance Alert provides a quick overview of the additional requirements contained in the Scheduling Letter now in effect.
The newly posted Item 19 FAQs reveal more about the support data and compensation policies and practices information that Federal contractors must submit at the onset of an OFCCP audit. Whereas aggregated compensation data was submitted during compliance reviews in the past, the new Scheduling Letter requires contractors to include employee/individual-level compensation data for all employees in the initial audit response package submitted to OFCCP within 30 days of the date on the Scheduling Letter.
Federal contractors and subcontractors would do well to familiarize themselves with the new requirements, especially the information provided in the new FAQs. As always, the MALY staff is happy to discuss OFCCP compliance initiatives with anyone interested in learning more about them.