The Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) will sometimes conduct audits to ensure equal opportunity in the workplace. The audit process is thorough and ranges from paperwork reviews to an on-site audit that ensures compliance with postings of current EEO notices. An audit does not necessarily mean that there is anything wrong; it is just a best practice to help agencies and contractors stay above board. Knowing what you can expect from a federal contractor compliance audit can make the process go much smoother.
Preparation Process
The compliance officer (CO) in charge of your audit will use a Standard Compliance Evaluation Report (SCER) to document the audit. The document provides the framework for the audit so that all agencies and contractors are held to the same standards.
The CO fills out the first section of the SCER in preparation for the audit. They will then gather knowledge about your agency or company, including any previous issues with compliance and all of your company’s basic information. They will also note if you are working with another agency or contractor during the compliance evaluation.
During this time, your agency or company may want to contact another agency that can help with Section 508 compliance to assist with the audit and ensure that everything that the CO needs is ready to go.
Desk Audit
The next section of the SCER covers the desk audit. During the desk audit, the CO will review a number of items, including:
- Itemized listing data for inclusion and acceptability
- Affirmative action programs
- Employment activity (hiring, termination, etc.)
- Utilization analysis and outreach assessment
- Vietnam Era Veteran’s Readjustment Assistance Act (VEVRAA) outreach assessment
The CO is looking for updates, progress, and certain benchmarks to ensure that the agency or company is making a good faith effort towards implementing these programs.
If the CO finds anything to be unsatisfactory, they will work with your agency or company to create an On-Site Plan and resolve any issues.
On-Site Review
The on-site review allows the CO to assess the implantation of EEO clause requirements, including whether appropriate signage is hung up in ready view of all employees and whether guidelines are being followed with regard to discrimination based on race, sex, disability, nationality, and religion.
The CO will document any issues they find, discuss them with you, give you an action plan, and expect your agency or company to quickly and fully implement it.
What the OFCCP is Looking For
Ultimately, the OFCCP is looking for a few things. They want to see what your personnel structure looks like and if your policies and procedures are fair and accessible. They also want to ensure that there is no discrimination taking place.
Additionally, they want to know that your agency is making progress towards its goals and has all of the information necessary to create a fair and equal workplace.
These audits require a lot of documentation and preparation on the part of the agency or the company. At Applied Development, we have the knowledge and experience to help you prepare for the audit process. If you have questions or would like to schedule a consultation, give us a call today at (410) 571-4016 or use the online Contact Us form.