Time: 1 hour
This comprehensive web training covers background information and strategic considerations essential for contractors engaged in an OFCCP compliance review. These strategies are aimed at demonstrating compliance with Executive Order 11246, Section 503 of the Rehabilitation Act of 1973 and the Vietnam Era Veterans Readjustment Assistance Act of 1974 (VEVRAA). First, strategies are explored for the initial submission of items requested by the OMB-approved itemized listing that accompanies an OFCCP compliance review scheduling letter. Second, additional strategies and considerations are explored related to common follow-up requests proposed by OFCCP during the desk audit phase. Finally, recommendations are made for onsite review preparation and managing the conclusion of an audit.
Main topics include:
- Introduction & Regulatory Context
- Communication & Process Notes
- Responding to a Scheduling Letter
- Preparing for and Responding to Follow-Up Requests
- Preparing for and Navigating an Onsite Review
- Possible Outcomes of a Compliance Review
- Final Notes
Michael Aamodt, Principal Consultant at DCI Consulting Group, wrote an article featured in SIOP’s TIP publication, January 2017.
Between the periods of 2005-2007, OFCCP had several open compliance reviews with Pilgrim’s Pride Corp. establishments. In just the last month, three DOL administrative complaints for audits from this period were dismissed. Dismissals resulted from Pilgrim’s Pride bankruptcy filed in 2008.
In December of 2008, Pilgrim’s Pride declared bankruptcy, and proceeded through the process, effecting a bankruptcy plan in December of 2009. As part of the bankruptcy plan, the Court gave notice of Pilgrim’s Pride bankruptcy available to all relevant parties, requesting that all parties submit claims by June 2009. OFCCP filed a claim alleging discriminatory practices at Mount Pleasant and Lufkin, TX, factories in May of 2009. Pilgrim’s Pride then filed a Claims Objection Procedures Motion to OFCCP’s claimsRead More