OFCCP AUDIT

A DCI Client receives an OFCCP audit scheduling letter

Problem

An international federal contractor had an intense OFCCP desk audit at a 20,000 person establishment. After DCI Consulting helped the contractor prepare and submit compliant, audit-ready documents, the OFCCP compliance officer sent the contractor a 51-factor request for additional information. This request included personnel data, compensation information, and performance information; and the deadline was set at two weeks, which included a federal holiday. Furthermore, the compliance officer scheduled an on-site review of the establishment and indicated that there was adverse impact in several applicant job groups. The compliance officer hinted that the adverse impact flags could be pursued as a failure to hire case.

Consulting Process

DCI consultants worked with the client and OFCCP compliance officer to establish reasonable deadlines for the 51 item request and creating timelines for submission documents. Additionally, DCI worked to narrow the scope of the requests by negotiating with the compliance officer on required documentation per regulatory guidance. Furthermore, DCI consultants and analysts conducted additional adverse impact statistics. The additional statistics narrowed the scope of the OFCCP flagged applicant job groups to just a few job titles. From this point, DCI assisted the client in explaining, and showing through advanced statistics, that all hiring decisions were based on job related and non-discriminatory requirements. DCI also provided on-site audit support and assisted the contractor in preparing for the OFCCP’s visit. Consultants prepared the establishment’s managers and HR staff, conducted a pre-audit facility walk-through, and supported managers during OFCCP interviews. With DCI support, the on-site review went smoothly.

Results

After the desk audit and on-site review, the OFCCP compliance officer had a few additional requests. About a month later, the audit closed with a letter of compliance.

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