OMB finally approves new OFCCP scheduling letters

On April 3, 2020, the Office of Management and Budget (OMB) approved the Office of Federal Contract Compliance Programs' (OFCCP) updated scheduling letters for establishment reviews, compliance reviews, and Section 503 focused reviews. The new Vietnam Era Veterans' Readjustment Assistance Act (VEVRAA) focused review letter was also approved. Most of the changes the OFCCP originally proposed were not adopted for the final letters. Here's an overview of the changes:

• The assessments of personnel process and physical and mental qualifications in the establishment review scheduling letter were revised to eliminate the requirement that contractors submit dates for the most recent assessment and for the next scheduled assessment, replacing it with a "description of the review." The OMB eliminated the proposal that subcontractor identification and internal promotion pools be provided.
• There were no real changes to the compliance check scheduling letter. The OMB rejected the OFCCP's proposal to require contractors to submit their written affirmative action plans (AAPs).
• The Section 503 focused review scheduling letter's assessment of personnel process was revised to simply require a "description of the review" but will require contractors to provide a schedule for the physical and mental qualifications assessment. The letter requires contractors to submit the information electronically. The OMB did not approve the OFCCP's request that contractors submit applicant and employee level data or compensation data on disability or veterans self-identification.

OFCCP issues three new directives