New OFCCP Compliance Review Letter Increases Affirmative Action Requirements for Employers

The new compliance review letter, announced by the Office of Federal Contracts Compliance Programs (OFCCP) in 2011, has finally been approved by the Office of Management and Budget (OMB). With the new letter are some major changes that affirmative-action employers need to know.

  • Submission of employment activity will have to be done by race and ethnicity, instead of the broader minority/non-minority categories that could be used in the past.
  • Unsurprisingly, the greatest change is to the reporting of compensation. The compensation data will no longer be submitted in the traditional aggregate report. The new Itemized listing will require compensation to be submitted by individual employee and include additional information on job title, job group, and EEO-1 category.
  • The definition of compensation has also been expanded from base pay to include hours worked, incentive pay, merit increase, locality pay, and overtime pay.

The formal announcement of the new compliance review letter will be in tomorrow’s Federal Register. For more information, please contact MSEC’s Affirmative Action Planning Services at aaps@msec.org or 800.884.1328.