You just received notice from the Office of Federal Contract Compliance Programs (OFCCP) of an audit. Now what? Here are three steps you should proactively take to help you survive the OFCCP audit process.
Step 1: Be ready – at any time – to respond to the audit letter. If selected for a desk audit, you will have exactly 30 days to provide the agency with documentation. This means you should always have the appropriate records available to provide to the OFCCP if summoned.
During an OFCCP audit, you will be required to submit hiring data, including internal records related to your hiring practices. This includes – and is not limited to – compensation data, personnel files, and other policies and procedures. Be ready.
Step 2: Always be prepared to be audited at a moment’s notice. As a federal contractor or subcontractor, you are required to maintain data on job postings, specifically taking measures to hire without regard for race, color, sex, religion or national origin as well as qualified individuals with disabilities and protected veterans. Reaching these qualified candidates is not enough. You also have to have the documentation that these job posting measures have been met.
Working with job boards that focus on OFCCP compliance will help you reach these diversity candidates, as well as maintain and submit reports as required.
Step 3: Understand OFCCP compliance procedures. Federal contractors need to meet several criteria to meet OFCCP compliance as it relates to equal opportunity hiring and affirmative action planning. This includes: 1) proving that they are actively working with state career sites, 2) posting jobs to qualified diversity candidates; and 3) keeping up–to–date records of all applicants.
Make sure that your executive staff and hiring managers understand affirmative action and equal opportunity hiring practices, and are well–versed in the audit process.
