On September 28, 2011 the Office of Federal Contract Compliance Programs (OFCCP) submitted to the Office of Management and Budget (OMB) its “revised” scheduling letter and itemized listing with minor changes to the original submission in May. Contractors will once again have 30 days to submit comments before OMB gives final approval. Until final approval is given, the OFCCP is using the current scheduling letter.

As important as the proposed Itemized Listing is, it is the supporting statement they submitted that provides the rationale for their revisions or lack thereof. To get a sense of the mindset of the OFCCP here is a quote:

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