Key Changes to OFCCP Scheduling Letter

by Terri Swain

Audit requests in 2015 will look different and ask for more information, as the scheduling letter has changed.

Key changes:

Personnel activity (hires, promotions, terms, applicant flow) can be provided either by job group OR job title but if submitted by title, you must also include department and job group (we’ve always provided by job group, with break down by requisition/hiring decision if preliminary adverse impact is indicated)

“Promotion” must be defined (we’ve always done this informally, but will have to be spelled out in the submission)

Race categories:  The scheduling letter refers to the previous five race categories but allows the 7 from EEO-1 reporting (we’re unsure why anyone would use the old 5 categories when all systems have been changed to the 7 several years ago)

Compensation Data request has expanded and must be submitted electronically (please note we have seen most of these requests in the last two years after the initial data sent):
· Employee definition: anyone on your payroll including contract and temporary workers that you pay as W9 employees. You do not have to include W2 independent contractors or agency temps – they are not your employees.
· Must include: base pay/rate (FTE, Annual, or Hourly rate is acceptable); hours worked per week (typical week); bonuses; incentives; commissions; merit increases; locality pay; overtime; race (5 or 7); gender; hire date (FAQ states most recent hire date; original hire date or service date can also be submitted if it would impact decisions); EEO-1 category; and job group

NEW! Accommodation policies and requests with resolutions – make sure you are tracking all accommodation requests.

NEW! Proof of periodic review of personnel procedures. This has always been a requirement in the AAP, but now they will be asking for documentation that it has been completed along with action items (see us for some ideas for completing).

As always, we are here to assist you through the audit process.