OFCCP Compliance Audit Requirements and Guidelines
Every year the federal government issues thousands of scheduling letters. FACF has successfully closed 100% of every audit that our clients have received in every region throughout the United States.
Our staff of Compliance professionals maintains an excellent working relationship with federal compliance officers in all regions of the US. We walk the walk and talk the talk. We have insider information that our competitors simply don’t have.
the federal government is relentless in audits and finding financial remedies. We all know that and federal audits are unlike anything experienced before–just as painstaking as an IRS Audit–and, in some cases, even worse.
One such federal department is the Department of Labor they will be well-armed and loaded with its own high-powered statisticians and compliance officers. As our client, you will be equally supported by a highly experienced, devoted compliance experts. Our mission is to ensure the very best outcome in every audit situation.
FACF experts have defended our clients with 100% closure rate and no financial payouts.
None of our clients have ever been forced to pay or make whole relief for a plan that we developed and defended.
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OFCCP Mock Desk Audit
This is where our experience as former compliance auditors really shines. Our Desk Audit is a two-tier process. First, we dissect your data as if you were going through an Federal desk audit. We address possible violations. We will also provide a comprehensive narrative detailing how to avoid any violations.
Who needs OFCCP Compliance Audit?
Federal contractors and subcontractors with 50 employees and $50,000 in government contracts are required to develop, implement and maintain AAP’s while providing goods and services to the federal government.
Why you need AAP Consulting?
Employment audits and corporate compliance are required to satisfy the equal-employment opportunity/affirmative action responsibilities for minorities and women under Executive Order 11246, as amended; people with disabilities under section 503 of the 1973 Rehabilitation Act; and covered veterans under the Vietnam Era Veterans’ Readjustment Act of 1973.
If your Government bills of lading totaling $50,000 or more in 12 months aggerates. In many cases, companies are required to implement an Affirmative Action Plan without a direct government contract. If government contractors purchase at least $50,000 worth of goods to fulfill their obligations on a government contract, then the goods’ seller is also subject to the OFFCP’s laws.
A gas station takes a government issued credit card. A hotel takes a government credit card are just some prime examples. A company furnishes a widget to a prime contractor who has a government contract. Even though there’s no direct contract with the government the company, if it exceeds $50,000 total revenue on those deals, then both sides must comply with Affirmative Action law.
Depository of government funds
Any financial institution, employing at least 50 people, with federal share and deposit insurance (including FDIC) is considered to be a government contractor, and therefore fall under Affirmative Action ordinances. This covers nearly every bank in the United States.
How we are going to help you?
We will advise and consult you in chosen the right vendor to develop and Implement an Affirmative Action Plan one that is cloud-based and contains the narrative and statistical components. The narrative is a detailed description of the practices of an organization in support of the good faith efforts to protect women, minorities, veterans, and disabled employees from discrimination in hiring practices both intentional and impactful. The statistical component includes the following analyses:
Workforce Analysis – listing of job titles in the organization classified into organizational units or workgroups.
Job Group Analysis – listing of each job title in the organization in terms of job groups and identifies the number of female and minority incumbents in each job group.
Availability Analysis – determines the availability of women and minorities by considering a reasonable recruitment area and promotions possible in the organization.
Utilization Analysis – compares incumbent women and minorities with available women and minorities and identifies areas of underutilization.
Adverse Impact Analysis – determines the statistical indication of adverse (disparate) impact against a protected class and analyzes the HR flow in all aspects of employee selection, promotions, and terminations.
Placement goals must be set when the percentage of minorities or women in a job group is less than reasonably expected given their availability percentage in that job group. Placement goals equal the availability percentage and serve as targets that organizations can meet through good-faith efforts and action-oriented programs.
Compensation Data Analyzed
OFCCP has also suggested that contractors adopt this process for their internal analysis.
- SSEGs
- Initial Screening
- Multiple Regression
The Need to Create Similarly-Situated Employee Groupings (SSEGs)
OFCCP has suggested to contractors to develop a new grouping method for compensation analysis. These groupings, which are known as SSEGs, should combine employees with: Similar Work, Level of Responsibility, Skills, and Qualifications.
SSEGs should have a minimum of 30 employees and have at least five of whom should be minorities or females.
Initial Screening for Potential Discrimination
The initial screening for potential discrimination consists of comparing the average salaries of minorities and non-minorities, females and males. A 5% difference in mean salary is a positive indicator that discrimination may exist and shows a potential need to use Multiple Regression Analysis.
Although this definition sounds very similar to the definition of an AAP Job Group, the OFCCP has stated that Job Groups may not be suitable for use as SSEGs. An example of this cited by the OFCCP would be two employees having identical job titles but very different levels of responsibility.
Multiple Regression Analysis to Statistically Validate Discrimination
Regression analysis involves identifying all of the independent variables that may affect salary (such as tenure, performance appraisals, education, etc.). A regression analysis should be performed on each of these variables to see if it explains the differences in pay. If disparities in compensation cannot be explained through regression analysis, then the contractor should document its findings and, if necessary, take action to remedy the situation. For many HR and Compensation analysts, multiple regression analysis is a highly complex statistical process that usually necessitates the use of specialized software or outside guidance.
Why you choose us?
We have over 110 years’ experience and expertise and is our passion. Our staff consists of Compliance professionals.
Our work process?
If need be we will be with you every step of the way We are all-inclusive and provide 24/7 support.
Basic Requirements (checklist)
Required for Initial Submission (Compulsory)
- Employee data for the required period including compensation as of 1st day of the new AAP year
- Applicant flow logs for the required period
- EE0-1 reports for the last three years
- VETS-100/100A report for the most recent year
- Assessment documents for outreach and recruitment efforts for Section 503 and 4212
- Accommodation policies and logs
- Any supporting documentation to show specific, targeted outreach efforts and action-oriented programs to meet unmet AAP goals (documentation of recruiting efforts specific to areas of underutilization in the plan)
- EEO Policy Statement indicating top US executive support
- Union information
- If you have a union, you will need a copy of the bargaining agreement and the name, address, and phone number of the union steward.
Nice to Have (Optional)
- Postings with state employment service delivery system
- Copy of online or newspaper ads showing EO tagline
- List of places from which you recruit
- Company overview including company logo or printed on letterhead
- Copy of purchase order with affirmative action verbiage
- Policies on maternity leave, FMLA leave, harassment
- “EEO is the Law” poster for applicants and employees
- E.O. 13496 poster (employee rights under Federal labor laws)
- Online accessibility statement
Our service is to have complete customer satisfaction and is our primary goal. Your dedicated consultant will always be available year-round to answer any questions you as a client may have.
First Advantage Consulting Firm is a service-disabled Veteran-owned small business.
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