The document outlines the steps and strategies for managing an Office of Federal Contract Compliance Programs (OFCCP) compliance review. It discusses responding to the notice of audit, preparing documentation for the desk audit, cooperating with an on-site review if required, and working with the OFCCP to resolve any issues identified in the review process. Possible outcomes include closure of the audit with no findings, findings of violations requiring corrective actions, or in rare cases, debarment from future government contracts.

1. OFCCP Compliance Review Steps and Strategies

2. #1 Rule for Managing an OFCCP Audit Know your AAP before you send it to the OFCCP

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. Stages of an Audit Desk Audit On-Site Review Off-Site Analysis

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. 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. 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. 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. OFCCP News, Trends And Cases That Impact 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. 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_letter.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. Contact Info Carla Irwin Carla Irwin & Associates, Inc. [email_address] 815-254-0690 www.carlairwininc.com