Received your official OFCCP scheduling letter for an upcoming audit? Do not panic because we got you covered. In this article, we shall discuss some simple steps in which you can prepare your organization for an OFCCP audit. Before that, let’s take a quick glance at what the OFCCP guidelines are.
What are OFCCP guidelines?
OFCCP guidelines are guidelines issued by the Office of Federal Contract Compliance Programs to ensure the availability of jobs to the minority sections of society. The guidelines have the primary objective of ensuring that equal opportunities are available for persons with disabilities, veterans, women, and other such sections of society.
3 steps to prepare for an OFCCP Audit
#1. Plan before the Review Process
In order to plan before your review process, it is important to understand the parameters on which your organization will be evaluated by the OFCCP. OFCCP primarily focuses on the following aspects:
- Personnel Activity: It includes all data regarding hiring, promotion, and termination. It is essential as this data contains any evidence of possible discrimination or any disparity in the employment process of your organization.
- Compensation: Specific information about how decisions regarding compensation or pay are taken is analyzed by OFCCP to address pay equality concerns.
- Technical and Affirmative Action (AA) compliance: Your organization must be compliant with the AAP requirements such as proof of listing with state agencies, good faith reports, availability analyses, policies documentation, and the like.
Before your OFCCP audit, ensure that all the required documents are in place. Tell the story of your efforts to preserve equity by ensuring that all your colleagues are well-versed with your policies and efforts. You can also appoint a consultant to review your plans before the audit.
#2. What to expect in the Audit?
OFCCP audits can take place in several forms, ranging from compliance checks to simple reviews. Establishment and functional plan reviews are comparatively more comprehensive than the aforementioned forms. Moreover, OFCCP may even conduct focused reviews such as compliance with VEVRAA or Section 503 of the Rehabilitation Act.
Once the organization submits all the necessary documents, OFCCP conducts an on-desk audit to evaluate all the documents. Following the on-desk audit, OFCCP may even schedule an on-site visit. Ensure that you are prepared to answer any and all questions that may be posed before and during the audit process.
#3. Cost of Non-Compliance
If all the documents and procedures adopted by the organization are compliant with the OFCCP guidelines, a notice of compliance is issued at the end of the review. However, in events of violation, the OFCCP can seek monetary remedies or debarment of a federal contractor from present or future contracts. Violations of OFCCP guidelines can be of three types – technical violations, compensation discrimination, or selection decision discrimination.
More and more organizations are becoming aware of AA compliance and increasing efforts to ensure equal opportunity facilities. If your organization is compliant with necessary AA requirements and is proactive in ensuring a diverse workforce, an audit by the OFCCP is a breeze.
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