Non-Material Change Request - Justification

OFCCP Recordkeeping and Reporting Requirements--Supply and Service

1250-0003

November 2018

Non-Material Change Request to OMB Control No. 1250-0003

The Office of Federal Contract Compliance Programs (OFCCP) is requesting a non-material change to OMB Control No. 1250-0003, Recordkeeping and Reporting Requirements - Supply and Service, to include a “focused review” letter as a new instrument. The proposed focused review will be conducted under the authority of Section 503 of the Rehabilitation Act of 1973, as amended, and its implementing regulations at 41 CFR 60-741. The instrument that is currently approved under this collection is the Scheduling Letter/Itemized Listing, which is the document OFCCP sends to federal contractors to initiate a compliance evaluation.

OFCCP’s regulations at 41 CFR 60-1.20, 60-300.60, and 60-741.60 state that the agency may conduct a compliance evaluation to determine if contractors meet their obligations under the regulations. A compliance evaluation may consist of one or any combination of the investigative procedures listed in the regulations, i.e., a compliance review, an off-site review of records, a compliance check, and/or a focused review. A focused review is smaller in scale compared to the compliance review that is initiated when a contractor receives the Scheduling Letter/Itemized Listing. Specifically, the proposed focused review letter requests approximately one-third of the information requested on the Scheduling Letter/Itemized Listing. Additionally, the letter does not contain any new questions that are not already part of the Scheduling Letter/Itemized Listing.

OFCCP will not conduct a greater number of compliance evaluations as a result of the implementation of the focused reviews as they will not be conducted in addition to, but in lieu of, compliance reviews in a number of instances. The agency anticipates that focused reviews will reduce burden on contractors because the proposed letter requests only a fraction of the information compared to the currently used instrument. OFCCP further anticipates that focused reviews will improve the compliance evaluation process by allowing the agency to use its limited resources to reach contractors, and consequently to be able to provide more compliance assistance where necessary.