Tuesday, September 15, 2020
On September 14, 2020, the Federal Register printed an data assortment request (“ICR”) by the OFCCP through which the company discloses that it “seeks authorization for an annual Affirmative Motion Program on-line certification course of for federal contractors and for a safe technique for federal contractors to submit AAPs electronically to OFCCP when they’re scheduled for a compliance analysis.”
Within the ICR, the OFCCP requests public touch upon its plan, noting it’s “significantly excited by feedback which:
Consider the proposed frequency and degree of knowledge assortment;
Consider whether or not the proposed assortment of knowledge is critical for the enforcement and compliance help capabilities of the company that assist the company’s compliance mission, together with whether or not the data could have sensible utility;
Consider the accuracy of the company’s estimate of the burden of the proposed assortment of knowledge, together with the validity of the methodology and assumptions used;
Improve the standard, utility, and readability of the data to be collected; and
Decrease the burden of the gathering of knowledge on those that are to reply, together with via the usage of applicable automated, digital, mechanical, or different technological assortment methods or different types of data know-how, g., allowing digital submission of responses.”
Feedback on the ICR are due by November 13, 2020 and could also be submitted right here.
The ICR is the most recent growth within the company’s efforts to ascertain an AAP certification course of. In 2018, the company issued Directive 2018-07, which introduced its intention to develop an Affirmative Motion Program Verification Initiative. As said within the Directive, the company views an annual AAP verification program as a approach to each encourage compliance and in addition focus the company’s audit efforts on these contractors doubtless not in compliance (i.e., those that fail to certify they’ve ready an AAP).
Two years after the issuance of the Directive, we nonetheless have no idea a lot concerning the specifics of this system apart from the company is working to implement it. We’ll proceed to observe and report on developments.
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