Career Resources, Inc. has identified some focus areas of recent OFCCP audits that would be helpful for all federal contractors to be aware of as they maintain their affirmative action programs. These focus areas include:
- Detailed data for the applicant, hire, promotion, and termination activity
- Detailed compensation data and investigation into identified pay disparities
- Description of the process that the company uses to ascertain race and gender of applicants
- Good faith outreach efforts for females and minorities
- Good faith outreach efforts for protected veterans and individuals with disabilities
- Documentation of job postings with appropriate state agencies
- Physical and mental job requirements for positions filled.
- List of reasonable accommodations provided to employees and applicants who are individuals with a disability
- Areas of adverse impact concerning applicants vs. hires, promotions, terminations
- Efforts to comply with the new regulations for protected veterans and individuals with disabilities that went into effect on March 24, 2014
To be prepared for an OFCCP audit, Career Resources, Inc. stresses the importance of the following:
- Keeping your AAP up-to-date
- Verifying the accuracy and integrity of your data
- Reviewing the results of your AAP analyses
- Implementing obligations as outlined in the AAP
- Making any necessary changes that were identified as potential areas of concern before an audit
- Maintain all required documentation, including outreach efforts, job postings, EEO 1 and VETS 100A reports, etc.
- If you contract with an employment/temporary agency, ensure that you maintain the appropriate records to comply with the recordkeeping requirements.
- Make sure that all policies are consistently applied