Following the initial comment period where it received feedback from the public on the proposed changes to the current scheduling letters, the OFCCP submitted revised scheduling letters for approval by the Office of Management and Budget (OMB). Gone are some of the more burdensome items that would have required federal contractors to supply promotion pools by race and gender. The requirement to provide the names of a prime contractor’s top three subcontractors has also been revised to only apply to subcontracts of $150,000 or more. Revisions to the Compliance Check and Focused Review letters were also proposed. The public is invited to send in their comments on this second round of Scheduling Letters by July 29.
In the meantime, OFCCP will continue to utilize the current versions of the Scheduling Letters for compliance reviews and have extended these on a month-to-month basis until OMB gives final approval.