The National Industry Liaison Group (NILG) recently communicated and worked with OFCCP’s national office to clarify contractor expectations during the COVID-19 pandemic. OFCCP has agreed to institute the following protocols for all contractors:
- Grant an automatic 30-day extension for submission of AAPs after receipt of Scheduling Letter
- Grant an automatic additional 30-day extension to contractors who submit their written AAP narrative within 60 days of receipt of scheduling letter (i.e. provide another 30 days for submission of all data reports and analyses)
- Grant an automatic extension of 14 days, and more commonly of 30 days, for contractor response to information requests, with opportunity for further extensions as needed
- Conduct 503 focused review onsites via video or phone conference only until contractors begin resuming normal operations
Additionally, OFCCP may grant further extensions to contractors whose ability to respond remains affected by the COVID-19 emergency. OFCCP and NILG recommend that contractors who believe OFCCP is not taking the pandemic emergency into sufficient account, either in general or in a relation to a specific audit, contact the OFCCP Ombud, Marcus Stergio, Stergio.Marcus@dol.gov.
OFCCP and NILG recommend that contractors concerned about receiving Scheduling Letters during the emergency consider providing an email address for the responsible contractor employee to the applicable Regional Director, with a copy to Deputy Director Patricia Davidson at Davidson.Patricia@dol.gov. OFCCP assures NILG that contractors providing this information will receive the Scheduling Letters via email in addition to the mailed copy.
By Joanna Colosimo, Director of EEO Compliance at DCI Consulting Group