The Office of Federal Contract Compliance Programs (OFCCP) has proposed changes to its scheduling letters for audits of federal contractors that would require contractors to share much more information with the agency.

"If the OFCCP is successful in adding even a fraction of these proposed changes, it will mean more work on the contractor during the course of a desk audit," said Joanna Colosimo, SHRM-SCP, vice president of workforce equity and compliance strategy and principal consultant with DCI Consulting Group in Washington, D.C.

If finalized, the proposal "will make compliance reviews much more burdensome and expensive for contractors," said Lynn Clements, director of audit and HR services with Berkshire in Columbia, Md.

Proposed Changes

There are at least 13 proposed changes to the scheduling letter, none of which reduce federal contractors' requirements, said Cheryl Behymer, an attorney with Fisher Phillips in Columbia, S.C.

She said that these proposed changes include:

• Increasing several protected categories to require data from the prior affirmative action plan (AAP) year, not just the current AAP year being audited. So, the contractor would need to provide the prior year's placement goals and the prior year's compensation data. The contractor also would have to include numerous other compensation-related data points, not just base salary. This means the contractor would be "providing twice the reports in these areas as it had been required to provide...

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