The Office of Federal Contract Compliance Programs (OFCCP) recently sent its regional offices a new list from which the agency will schedule its compliance evaluations of non-construction federal contractors beginning in October 2005.
The Office of Federal Contract Compliance Programs (OFCCP) recently sent its regional offices a new list from which the agency will schedule its compliance evaluations of non-construction federal contractors beginning in October 2005. The list was generated through the OFCCP's Federal Contractor Selection System (FCSS) that uses seventeen factors comparing the workforce profile of a contractor's establishment to that of establishments in the same industry classification and to the local labor market reflected in 2000 Census data.
The list is made up of facilities that are federal contractors and have 150 or more employees. The list does not include establishments that are currently undergoing compliance evaluation or that were evaluated within the last 24 months. The OFCCP has modified its 25-cap rule to apply independently of the number of open evaluations for a single contractor. The OFCCP now states that it will not schedule more than 25 new evaluations of a single contractor's establishments in a given year, even though there may be a number of open evaluations.
If a contractor has more than one establishment on the OFCCP's list, the agency will send a Corporate Scheduling Announcement Letter to the contractor's headquarters identifying the establishments that are on the list. This letter is notice to the contractor that some of its establishments are on the list scheduled to undergo a compliance evaluation within the next 12 months. It is not a letter scheduling a compliance evaluation.
Ford & Harrison attorneys can help you prepare for a compliance evaluation and consider the merits of any compliance assistance offered by the OFCCP. If you have received a Corporate Scheduling Announcement Letter or have any questions regarding the OFCCP's affirmative action or other record-keeping requirements, please contact Karin Verdon, (303) 592-8865, or the Ford & Harrison attorney with whom you usually work.