Do you know what type of OFCCP evaluation your company will undergo?
The Office of Federal Contract Compliance Programs (OFCCP) is responsible for reviewing and enforcing federal contractor compliance with equal employment opportunity and affirmative action requirements.
If you’re wondering what to expect during an OFCCP evaluation, it’s best to educate yourself about the process. In this blog, you’ll learn about the different types of compliance evaluations that OFCCP conducts on government contractors and subcontractors.
Types of OFCCP evaluations
The audit begins with the OFCCP sending a scheduling letter with requests for information related to:
- A copy of your AAP( Affirmative Action Plan)
- A list of applicants, including their gender, national origin, and race
- Recruiting activities
- Promotion and compensation data
- Termination data
You will be required to provide the information within 30 days of receiving the request. Once this is done, the evaluation can involve any one or more of these investigative procedures.
The review can occur in three stages – desk audit, off-site analysis, and on-site review.
Desk audits are typically the most commonly used type of OFCCP audits. This is a comprehensive evaluation of the government contractor’s practices, including their AAP (affirmative action program), and the consequences of this program.
Depending on the findings of the desk audit, the review process may close at this stage or proceed to a more detailed on-site or off-site review (or both).
Off-site and on-site reviews
An off-site review of records involves examining the AAPs and related documentation in addition to your personnel policies and hiring activities.
An on-site review involves a detailed analysis where the OFCCP conducts facility tours, interviews hiring managers, and examines required postings.
Corporate Management Compliance Evaluation
This evaluation is focused on finding out if employees in your company are encountering barriers to progressing into top/mid-level corporate management roles.
Preparing for the audit
In order to be in compliance with OFCCP and prepare for the audit, you will need to ensure the following:
- Recordkeeping– Collecting, analyzing, and maintaining personnel activity data that includes hiring, rates of pay, assignments, promotions, transfers, terminations, training, demotions, and training.
- Adding an EEO tagline in job ads – Ensure your job postings always have an EEO tagline stating you are an EOE or Equal Opportunity, Employer.
- Self-disclosure – Invite employees and applicants to voluntarily self-identify as protected veterans or individuals with disabilities.
- Periodic reviews- Review all job qualifications to make sure those with disabilities are not barred from applying solely on the basis of their disability. Also, maintain the records detailing the results of this review and any corrective action you took.
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