OFCCP Compliance Review Steps and          Strategies
#1 Rule for Managing an OFCCP Audit• Know your AAP before you send it to  the OFCCP
Notice of Audit• Corporate Scheduling Announcement  Letter (CSAL)  – Use this notice to your advantage• Scheduling Letter ...
Stages of an Audit• Desk Audit• On-Site Review• Off-Site Analysis
Desk Audit• Submission of complete and accurate information  requested in scheduling letter to OFCCP office  within 30 day...
On-Site Review• Every 25th review will be chosen for full audit  regardless of indicators (on-site included)• Indicators o...
Off-Site Analysis• Documents determined to be necessary  from on-site review are reviewed off-  site• Keep in touch with c...
Possible Outcomes/Closure of Audit• Closure Letter (with or without  violations)  – Audit closed, no further action requir...
OFCCP News, Trends And Cases ThatImpact An Audit•   Rescission of Active Case Management•   Active Case Enforcement•   Res...
Resources• Sample Corporate Scheduling  Announcement Letter  – http://www.dol.gov/ofccp/regs/compliance/csal_letter.pdf• S...
Contact Info•   Carla Irwin•   Carla Irwin & Associates, Inc.•   cirwin@hrlinkgroup.com•   815-254-0690•   www.carlairwini...
Upcoming SlideShare
Loading in …5
×

ci newsletter

754 views

Published on

  • Be the first to comment

  • Be the first to like this

ci newsletter

  1. 1. OFCCP Compliance Review Steps and Strategies
  2. 2. #1 Rule for Managing an OFCCP Audit• Know your AAP before you send it to the OFCCP
  3. 3. Notice of Audit• Corporate Scheduling Announcement Letter (CSAL) – Use this notice to your advantage• Scheduling Letter – Get started ASAP – 30 days to respond – Identify resources (internal & external)
  4. 4. Stages of an Audit• Desk Audit• On-Site Review• Off-Site Analysis
  5. 5. Desk Audit• Submission of complete and accurate information requested in scheduling letter to OFCCP office within 30 days• Thoroughly review documentation/recordkeeping• Attention to EO 11246, Section 503 & VEVRAA requirements• Adverse impact analysis – Validate & refine• Conduct compensation analysis• Highlight your accomplishments/good faith efforts• Document all conversations with compliance officer
  6. 6. On-Site Review• Every 25th review will be chosen for full audit regardless of indicators (on-site included)• Indicators of potential areas of discrimination or noncompliance with affirmative action requirements• OFCCP visits contractor’s facility to inspect personnel documents and practices• Can include interviews with employees and managers• Review every document supplied to compliance officer• Company representative, including attorney should be present at management interviews
  7. 7. Off-Site Analysis• Documents determined to be necessary from on-site review are reviewed off- site• Keep in touch with compliance officer• Give OFCCP reasonable amount of time to complete review of data• Have appropriate resources to prepare for negotiation and conciliation with OFCCP
  8. 8. Possible Outcomes/Closure of Audit• Closure Letter (with or without violations) – Audit closed, no further action required• Notice of Violations• Conciliation – Reporting – Make-whole relief – Debarment
  9. 9. OFCCP News, Trends And Cases ThatImpact An Audit• Rescission of Active Case Management• Active Case Enforcement• Rescission of I-9 form inspection• Rescission of comp guidelines• Frito-Lay case – Desk audit requests limited to time frame in scheduling letter• Increased focus on veteran/disabled outreach• Increase in enforcement – Multi-establishment complaints and conciliation – Pursuing individual complaints and classes of 2 or more – Debarment
  10. 10. Resources• Sample Corporate Scheduling Announcement Letter – http://www.dol.gov/ofccp/regs/compliance/csal_letter.pdf• Sample Scheduling Letter – http://www.dol.gov/ofccp/regs/compliance/OMB_appr_let ter.pdf• Federal Contract Compliance Manual – http://www.dol.gov/ofccp/regs/compliance/fccm/fccmanul. htm• Active Case Enforcement Directive – http://www.dol.gov/ofccp/regs/compliance/faqs/ACE_faqs .htm#Q6
  11. 11. Contact Info• Carla Irwin• Carla Irwin & Associates, Inc.• cirwin@hrlinkgroup.com• 815-254-0690• www.carlairwininc.com

×