On August 24, 2022, the Office of Federal Contract Compliance Programs (OFCCP) announced that it had updated its guidance for educational institutions with federal contracts and/or subcontracts. The updated guidance is included in the Contractor Portal frequently asked questions (FAQs) page concerning registration at FAQ 4 and OFCCP Contractor Portal Federal Contractor User Guide at pages 8 and 12-14. The updated guidance requires federal contractor and subcontractor educational institutions to register using both their Integrated Postsecondary Education Data System (IPEDS) unique identification number (UNITID or IPEDS ID) and Employer Identification Number (EID). OFCCP's Contractor Portal Technical Help Desk has confirmed that educational institutions that are already certified in the Contractor Portal should update their portal registration information to include their institution's IPEDS ID.
Ogletree Deakins' Affirmative Action and OFCCP Compliance Practice Group will continue to monitor developments with respect to the OFCCP's contractor portals—including the new Notification of Construction Contract Award Portal (NCAP)—and will post updates on the firm's Affirmative Action / OFCCP and Government Contractors blogs as additional information becomes available. Important information for employers is also available via the firm's webinar and podcast programs.
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