OFCCP Revises Scheduling Letter for Federal Construction Contractors

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The U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has issued a revised Construction Scheduling Letter, effective October 1, 2024. This letter will impact federal and federally assisted construction contractors and subcontractors through July 31, 2027. OFCCP says that the revised letter offers improved clarity and more efficient data requests, but others say it increases contractors’ reporting burden.

Contractors must provide payroll data beyond base pay and report details on employee lay-offs. Contractors must also disclose the use of technology-based tools such as artificial intelligence, algorithms, or automated systems. For companies with direct federal contracts, additional requirements related to Section 503 (addressing individuals with disabilities) and VEVRAA (for protected veterans) can apply.

The new scheduling letter applies to contractors undergoing construction compliance reviews on or after October 1, 2024. A copy of the Scheduling Letter can be found at: https://www.dol.gov/sites/dolgov/files/OFCCP/FCCM/Construction%20Scheduling%20Letter%20Effective%20Oct%201%202024%20508c.pdf