Apart from investigating complaints, the Office of Federal and Contract Compliance Program (OFCCP) within the Department of Labor selects about 2,000 to 4,000 contractor and subcontractor establishments for compliance audits each fiscal year. The government imposes stricter affirmative action standards on government contractors than on the private sector. The purpose of the OFCCP audit is to ensure that these standards are met.
All federal contractors and subcontractors with 50 or more employees and a single contract of $50,000 or more must annually write an affirmative action plan covering women and minorities for each of their establishments. Upon receiving a notification from the OFCCP scheduling an audit, a company is given a 30 day window in which to gather all supporting documentation related to adherence to affirmative action obligations. While analyzing the data in a desk audit, the OFCCP may ask for additional information and may even wish to conduct an on-site audit.
Considering that the OFCCP collected $11.9 million in 2014 in recovery of back pay, federal contractors bound by the need to showcase their Affirmative Action plans need to do more than just implementing them. To effectively face an OFCCP audit, a federal contractor will have to also document their good faith actions in implementing their affirmative action plan and achieving its professed objectives. These could be:
Remember that poor recordkeeping comes right behind discrimination in hiring and compensation in every instance of non-compliance penalized by the OFCCP.
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