OFCCP Proposes Promotion & Accommodation Focused Review Letters

OFCCP has proposed new scheduling letters for the Promotion and Accommodation Focused Reviews. Similar to the final letters for the Section 503 and VEVRAA focused reviews, these letters are condensed versions of the standard compliance review letter, with no new items added to the letter. Given the non-material changes it is anticipated that the Office of Management and Budget will approve the letters.

Both letters require submission of the written narratives for Executive Order 11246, Section 503 and VEVRAA in addition to the supporting data per the itemized listing. The proposed itemized listing for promotion reviews includes 11 items, while the accommodation review listing includes 8 items. Notably, both reviews require submission of employment activity (applicants, hires, promotions, and terminations) and employee-level compensation data.

As a reminder, both promotion and accommodation reviews were included on the most recent Corporate Scheduling Announcement List (CSAL), posted September 11th and revised September 16, 2020. OFCCP included 500 establishments each for the promotion and accommodation reviews, with these reviews randomly sorted at the bottom of the list. A total of 2,250 establishments were included on the 2020 CSAL.

Additional information can be found on the OFCCP landing pages for both the accommodation and promotion reviews. As noted in September, many of the quick link resources are “coming soon”, but both pages provide a window into what can be expected in each review. Notably, promotion reviews may focus on intersectionality (e.g., women of color) to determine whether opportunities for advancement are being limited. Accommodation reviews will focus on both religious and disability accommodation with an emphasis on denied accommodation requests. Both promotion and accommodation landing pages outline the expectation that Compliance Officers will interview managers and affected employees and applicants.

Stay tuned for additional information.

By Amanda Bowman, Associate Principal Consultant at DCI Consulting Group

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