1C01 Nonreceipt of Itemized Listing Data

If, in response to the Scheduling Letter and Itemized Listing, a contractor does not meet its deadline to submit all the Itemized Listing records requested, including employment activity data, the Investigator must immediately recommend issuing a SCN. Investigators can find the procedures for issuing a SCN in Chapter 8 – Resolution on Noncompliance. Examples of incomplete information include not submitting data for one or more personnel activity elements, such as applicant flow, hires, compensation, promotions or terminations. As with all correspondence, conversations, emails, or other communication, this contact must be meticulously recorded in the case correspondence, in the event OFCCP goes to litigation.

If a contractor submits its AAP(s), but does not submit the Itemized Listing, the Investigator should determine if the AAP(s) are acceptable and begin the process to issue a SCN regarding the missing Itemized Listing submission and any unacceptable elements of the AAP(s). If the contractor submits its AAP(s) and partial Itemized Listing data, the Investigator should determine if the AAP(s) and partial Itemized Listing submissions are acceptable and analyze the acceptable Itemized Listing data submitted. The Investigator and supervisor should determine if a SCN is necessary to receive the missing Itemized Listing data.