On August 24, 2023, the Office of Information and Regulatory Affairs, part of the Office of Management and Budget (OMB), announced a decision marked as “Approved with Change” towards the proposed revisions of the Office of Federal Contract Compliance Programs (OFCCP) scheduling letter for supply and service contractors.
These revisions are significant as they outline the terms and conditions to which supply and service contractors must adhere to during their contractual period. The OFCCP is responsible for ensuring that employers doing business with the Federal government comply with the laws and regulations requiring non-discrimination and affirmative action. Their regulatory domain includes companies that hold federal contracts and subcontracts, impacting a considerable proportion of the business landscape.
The exact changes have not been detailed yet. However, DCI Consulting, a human resource consulting firm that aids organizations to form proactive approaches to equal employment opportunity compliance, is currently working on a comprehensive comparative analysis against the prior version.
This analysis will provide an insight into the implications of the new modifications and will be invaluable for legal professionals advising supply and service contractors, in addition to the contractors themselves. It is anticipated that this will prompt companies to review and potentially adjust their current procedures and policies, underlining the importance of this Approved with Change decision by the OMB.