OFCCP has announced changes to the Supply and Service Scheduling Letter and Itemized Listing. The new Scheduling Letter clarifies some existing requirements but also requires contractors to submit additional information and support data to demonstrate compliance during an audit. Some of these new requirements include:
- Post-Secondary Institutions and Federal Contractors with “campus-like” settings that maintain multiple AAPs will be required to submit the requested information for all AAPs developed for the institution located in the city and state of the establishment under audit.
- Post-Secondary Institutions will be required to submit IPEDS data collection reports for the last 3 years.
- Federal Contractors will be required to include documentation of how artificial intelligence, algorithms, and other automated technology are used in selection procedures.
- Contractors will provide detailed compensation information for two data snapshots (previously, only 1 was required), and specific details on when, how, and what forms of compensation were analyzed.
OFCCP will use the new scheduling letter for all compliance evaluations beginning August 24, 2023.
Berkshire is continuing to absorb the details of all changes; stay tuned to our blog for more information on the newest requirements.