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Are You Prepared for Your OFCCP Audit?
Are you ready for an audit? If your organization does business with the Federal Government and if you’re required to comply with any of the below regulations or acts, you are one of over 200,000 businesses subject to an audit by the Office of Federal Contract Compliance Programs (OFCCP).
- Executive Order 11246, as amended
- Section 503 of the Rehabilitation Act of 1973, as amended
- Vietnam Era Veterans’ Readjustment Assistance Act of 1974, as amended
- OFCCP’s regulations at 41 CFR Part 60
- Applicable case law
Whether the audit is a Desk Audit or an On-site Review, there are four possible investigative procedures that will be included.
4 Types of OFCCP Reviews
1. Compliance Review
This is the most comprehensive review and will evaluate employment practices (including a review of some or all of your written and actual Affirmative Action Program (AAP)), supporting documents and the results of your affirmative action efforts. Depending on the circumstances or results of the initial desk audit, like determining if you comply with 41 CFR Chapter 60, the OFCCP may proceed with further data analysis or an onsite review.
2. Offsite Review of Records
Based on the desk audit procedures outlined by the US Department of Labor, this type of audit is a review of some or all of your written Affirmative Action Program (AAP) policies and actions.
3. Compliance Check
The focus of this review, which may be onsite or offsite, is to determine if you have maintained records in compliance with 41 CFR 60-1.12, 41 CFR 60-250.80, 41 CFR 60-300.80, and 41 CFR 60-741.80
4. A Focused Review
This is typically an onsite review that is focused on one or more aspects of your organization or your hiring practices.
What should you expect from an audit and how can you best prepare for one? Having appropriate documentation accessible will make the process much easier to coordinate.
How to Prepare for Your OFCCP Audit
- Review the Federal Contract Compliance Manual (FCCM) to fully understand what OFCCP Compliance Officers look for when