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OMB Approves Revised OFCCP Scheduling Letter

Client Alert | 1 min read | 10.03.14

Significant changes are just over the horizon for federal contractors and subcontractors, as OMB has approved the revised Scheduling Letter and Itemized Listing proposed by the Office of Federal Contract Compliance Programs. As further explained in the linked alert, the revised Scheduling Letter will require contractors, at the outset of a compliance review, to submit to OFCCP individualized compensation data, personnel activity data broken out by each racial subgroup (rather than in two groupings, minorities and non-minorities), and additional materials to demonstrate compliance with the new Veterans' Readjustment Assistance Act and section 503 of the Rehabilitation Act regulations that became effective earlier this year.


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Client Alert | 3 min read | 02.26.26

FERC Requires Refunds for Late QF Recertification

On February 19, 2026, the Federal Energy Regulatory Commission (FERC) issued Branch Street Solar Partners, LLC et al., 194 FERC ¶ 61,124 (2026) rejecting the refund reports filed in connection with the late filing of recertifications of qualifying facility (QF) status by certain affiliated companies to reflect a change in upstream ownership. FERC’s rearticulation of QF recertification timing requirements and consequences for late QF recertifications has broad and substantial implications for all QF owners. ...