HR Compliance Audit
As part of a proactive self-audit, a large federal contractor contacted DCI Consulting to conduct a mock OFCCP audit. The mock audit deliverables included: assessing their overall affirmative action program and EEO/AA policies, identifying strengths and areas of improvement, and preparing staff for potential ‘live’ audits.
Acting as OFCCP compliance officers, a team of DCI consultants developed a project plan that defined three phases: 1) Desk Audit; 2) Onsite Visit; 3) Debrief.
Desk Audit: Initiated with a scheduling letter, the desk audit phase included the client’s submission of all relevant affirmative action program documents within an established deadline. DCI reviewed the submitted material and sent follow-up requests where “problem areas” were identified.
Onsite Visit: DCI consultants scheduled an onsite visit, which included a tour of the contractor’s facility, an entrance conference with the highest-ranking official, staff interviews (Talent Acquisition, Compensation, Operations and Compliance), and a review of targeted policies. The focus of the onsite visit stemmed from any concerns and questions identified during the desk audit phase.
Debrief: At the conclusion of the project, an in-person debrief was held to review the results of the desk audit and onsite visit. DCI consultants addressed the client’s strengths, noted areas of potential risk, and provided recommendations for next steps.
The mock audit led to internal discussions and an implementable action plan that addressed the risk areas identified during the audit. The client felt readily prepared for future OFCCP audits.
Federal contractors can save money, time, and their company’s reputation by knowing what to expect during an actual OFCCP audit and ensuring that they are doing what is necessary to maintain compliance. DCI’s mock audits are designed to help federal contractors identify potential risk areas and bring them to light before experiencing the unfortunate consequences that come with OFCCP-identified violations.
Michael Aamodt, Principal Consultant at DCI Consulting Group, wrote an article featured in SIOP’s TIP publication, January 2017.
DCI has just learned that OFCCP began to send out audit scheduling letters on March 17th. At this time we are not certain how many were sent out, but we do know that 800 CSALs (Corporate Scheduling Announcement Letters) were sent to contractor establishments last month. It is critical that corporate compliance representatives notify individual establishments in their organization to be on the look-out for any official OFCCP correspondence. If you did receive a scheduling notice, please notify DCI immediately so that we can assist you with the audit process.
To read the audit distribution notice, please click here.
By Rosemary Cox, Senior Consultant at DCI Consulting GroupRead More