By: Evan Szarenski
OFCCP began the renewal process in December of last year, when it published the first notice for public comment. In the first notice, OFCCP proposed collecting the Unique Entity ID (UEI), which replaced DUNS, for each parent company and establishment. In the most recent supporting statement, OFCCP did not change this proposed requirement, but did provide additional detail.
OFCCP is proposing that there will be a question about whether the parent company or establishment has at least one UEI. If the contractor selects “Yes,” it will then need to insert the UEI (or one of its UEIs if there are multiple). Contractors with a DUNS number but no UEI will be able to enter the DUNS number instead. OFCCP’s new supporting statement clarifies that contractors without a UEI or DUNS number or who utilize Functional Affirmative Action Programs (FAAP), will not be required to provide one.
In addition to clarifying the UEI process, OFCCP is also seeking approval to permit, but not require, contractors to submit AAPs through the Contractor Portal in the event of an audit. This functionality was previously approved, but OFCCP never implemented the functionality. There is no indication when this functionality will be available.
Comments on the ICR are open until June 12, 2024 and can be submitted here. Once the comment period closes, the Office of Management & Budget (OMB) will review the proposal and comments, and either grant the extension (possibly with additional changes) or deny the extension.
DCI will continue to monitor the status of this proposal and provide updates.