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(answers below)
True or False?
Proposed changes to the OFCCP Compliance Evaluation Scheduling Letter and Itemized Listing:
1. The comment period for the proposed changes to the Scheduling Letter and Itemized Listing is closed.
2. Item 12 of the proposed itemized listing will require submission of more precise compensation data.
Notification of Employee Rights under the National Labor Relations Act
3. All private sector employers, subject to the National Labor Relations Act (NLRA), are required to post notices informing their employees of their rights as employees under the NLRA as of November 14, 2011.
OFCCP proposed rule: Affirmative Action and Nondiscrimination Obligations of Contractors and Subcontractors Regarding Protected Veterans
4. The proposed rule will require contractors to maintain referral, applicant and hire data for protected veterans as well as job opening / job fill data for a period of five years.
Answers
1. FALSE –The OFCCP comment period has closed, however The Office of Management and Budget is now requesting comments with regard to the OFCCP request for changes. The OMB comment period closes 10/28.
2. TRUE - The more precise data is individual employee data rather than the aggregate data requested in the current Scheduling Letter. Additionally, the data will be required “as it existed on the most recent February 1st date”.
3. FALSE - A Federal contractor will be regarded as complying with the Board’s notice posting rule if it posts the Department of Labor’s “Notice of Employee Rights”. Additionally the National Labor Relations Board has extended the date from November 14 to January 31, 2012
4. TRUE – The proposed regulation requires that contractors maintain several quantitative measurements and comparisons (including calculated ratios). The OFCCP believes that these measurements will provide “important information that does not currently exist” with regard to the number of protected veterans who are referred to or apply for jobs with Federal Contractors.
For information on the affirmative action compliance services offered by THOMAS HOUSTON associates, inc., call 1-800-330-9000 or click here to schedule a convenient time to receive a call from one of our Affirmative Action Consultants.
