OMB issued revised OFCCP scheduling letter for comment

On April 18, 2023, the Office of Management and Budget (OMB) issued a revised scheduling letter and itemized listing, with comments due on May 17, 2023.

In the original scheduling letter, the Office of Federal Contract Compliance Programs (OFCCP) had proposed that post-secondary institutions and federal contractors in campus-like settings with multiple affirmative action programs (AAPs) will be required to submit the information required by the scheduling letter for all AAPs developed for the campuses, schools, programs, buildings, departments, and other parts of the institution or company located at a specific city and state. The revised scheduling letter retains this language despite the lack of regulatory support for the requirement.

In the itemized listing, OMB made only a few changes to the very burdensome OFCCP proposal. The proposed itemized listing as revised would have the following additional requirements for federal contractors: