It's OFCCP audit time! Six questions contractors should ask themselves

Louise Davies is an Affirmative Action Paralegal in Constangy's Winston-Salem, North Carolina, office. For more than 15 years, she has helped employers develop affirmative action plans and respond to audits and on-site investigations by the Office of Federal Contract Compliance Programs. She also conducts diversity training for employers. Louise is a graduate of Wesleyan College in Macon, Georgia.

Starting February 17, the Office of Federal Contract Compliance Programs began mailing Corporate Scheduling Announcement Letters to approximately 800 contractor establishments. CSALs are notices sent to contractors advising them that they could be selected for a compliance evaluation. They are not SchedulingLouise Letters, which begin a compliance review. Rather, CSALs are intended to give contractors some advance time to prepare for potential audits. They are not required by law and are considered to be a courtesy to the contractor.

The OFCCP also began issuing actual Scheduling Letters on March 17. Are you ready for an OFCCP compliance review? Here are six things that contractors should ask themselves to ensure they are prepared:

  1. Is your data for applicants, hires, terminations, and promotions reconciled and accurate? Have you researched areas of potential adverse impact in these areas?

  1. Have you conducted a compensation analysis, and can you explain pay disparities that may exist? Are you compliant with the current equal pay laws?

  1. Are you able to provide proof of your good-faith efforts to recruit women, minorities, protected veterans, and individuals with disabilities?

  1. Have the Affirmative Action Plan results been communicated to managers and executives, and have they received the required training?

  1. Have you reviewed your company website through the eyes of a potential candidate to ensure its compliance with the current laws and regulations?

  1. Have you updated existing policies and posters to reflect recent regulatory changes?

If you have not done these things to ensure top-to-bottom compliance, now is a good time to begin the process. Let us know if we can be of any assistance.

Robin Shea has 30 years' experience in employment litigation, including Title VII and the Age Discrimination in Employment Act, the Americans with Disabilities Act (including the Amendments Act). 
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