OFCCP and DLR propose sweeping changes to construction compliance forms
The Office of Federal Contract Compliance Programs (OFCCP) and the German Aerospace Center (DLR) have both recently proposed changes to their respective forms and processes. OFCCP seeks to renew and modify Form CC-314 and its construction scheduling letter, while DLR aims to extend and restructure its construction supervision and planning documents.
OFCCP's proposed changes to Form CC-314, due to expire on July 31, 2024, include new requests for contract type, North American Industry Classification System (NAICS) code, and the Employer Identification Number (EIN). Additionally, contractors may be required to provide more information about new construction contract awards exceeding $10,000. The proposed changes to the construction scheduling letter involve submitting employment activity data electronically and clarifying enforcement actions for non-compliance within thirty days.
DLR, on the other hand, published an amendment draft on February 26, 2024, proposing an extension and restructuring of its construction supervision and planning documents. Comments on these proposals are due by April 26, 2024. Both proposals aim to enhance compliance and data collection in the construction industry.
Covered construction contractors should be prepared to provide additional data and documentation in response to the proposed changes. OFCCP's and DLR's changes, if implemented, will impact how contractors report and manage their compliance with regulations. Contractors are advised to review the proposed changes and provide feedback during the comment periods.
