DCI Consulting – On August 24, OMB posted an “Approved with Change” action for the Office of Federal Contract Compliance Program’s (OFCCP) revisions to its compliance review scheduling letter for federal supply and service contractors and subcontractors.
Despite significant concerns from federal contractors and subcontractors regarding the “campus-like settings” proposed change, OFCCP has retained that verbiage. The request for all AAPs that are part of one campus setting will result in significantly greater employee counts and more personnel actions with which the agency will run its analyses. There are also several items in the final scheduling letter that will create substantial burdens for federal contractors and subcontractors undergoing compliance reviews.
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