OFCCP Proposes Changes to Complaint Forms

The Office of Federal Contract Compliance Programs (OFCCP) is proposing changes to the forms used to...



Posted by Rachel Rubino, MS, SPHR, SHRM-SCP on July 9 2025
Rachel Rubino, MS, SPHR, SHRM-SCP

The Office of Federal Contract Compliance Programs (OFCCP) is proposing changes to the forms used to file complaints of employment discrimination by federal contractors and subcontractors.


The proposed changes would remove references to Executive Order (EO) 11246, which was revoked on January 21, 2025 with the issuance of EO 14173. Published in the Federal Register on July 7, 2025, OFCCP’s proposed revisions would modify questions on the Complaint of Employment Discrimination Involving a Federal Contractor or Subcontractor form (CC–4) and Pre-Complaint Inquiry for Employment Discrimination Involving a Federal Contractor or Subcontractor form (CC–390) to remove references to EO 11246. These forms would continue to be used to file complaints of employment discrimination with OFCCP related to Section 503 or VEVRAA.

 

OFCCP is seeking public comments on their proposed revisions. The notice states that the agency is interested in comments that speak to whether the collection of information on these forms is necessary for the proper functions of the agency, as well as if the information gathered on these forms has ‘practical utility’. OFCCP also requests comments that evaluate the accuracy of their estimates of burden related to information collection, suggest methods to ‘enhance the quality, utility, and clarity of the information to be collected’, and reduce the burden of the information collection on individuals using the form, including allowing electronic responses. Comments are being accepted until September 5, 2025, and will be accepted through electronic submission as well as hard copy paper submissions.

Rachel Rubino, MS, SPHR, SHRM-SCP
Rachel Rubino, MS, SPHR, SHRM-SCP
As Managing Consultant, People Insights at Berkshire, Rachel Rubino, SPHR, SHRM-SCP, specializes in helping companies of all sizes and industries meet their unique compliance and workforce analytic needs. With an in-depth knowledge of the changing compliance landscape, Rachel provides leading support and guidance to her clients—working to keep them up-to-date and compliant.

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