Long-anticipated policy changes that impose stringent new recordkeeping requirements on federal contractors for their compensation and hiring practices could lead to more discrimination cases.

In 2011, the Office of Federal Contract Compliance Programs (OFCCP)—the Labor Department division responsible for ensuring that contractors comply with Equal Employment Opportunity laws—proposed changes to its Scheduling Letter and Itemized Listing. Used in conjunction with an audit notification letter, it identifies the materials contractors must provide at the onset of an OFCCP desk audit. The changes stalled for three years while awaiting approval from the Office of Management and Budget (OMB).

Jaclyn Jaeger is a freelance contributor to Compliance Week after working for the company for 15 years. She writes on a wide variety of topics, including ethics and compliance, risk management, legal,...