EMPLOYMENT AUDITS

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Special Issues for Federal Contractors

The United States Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) has stepped up its efforts to ensure that Federal contractors are in compliance with all affirmative action requirements.

The OFCCP is now conducting spot checks on contractors to insure they are completing their Affirmative Action Plans and all required reporting. Contractors are sometimes given less than a week’s notice of an OFCCP visit, so it is essential for all Federal contractors to have an updated, compliant Affirmative Action Plan. Audits are on the rise and, with the advent of the controversial Equal Opportunity Survey, the OFCCP will maintain and monitor increased data on your company.

Affirmative Action Plans (AAPs) are produced once per year, and must be updated each subsequent year. The plan year can be a calendar year plan, fiscal year plan, or any date the contractor chooses. Affirmative Action Plans are required for all Federal government contractors and subcontractors with contracts in excess of $50,000, and who have at least 50 employees in a 25-mile radius. Companies should keep AAPs in line with EEO-1 reporting locations, so if a site is selected for audit, the statistics will be similar. For better statistical analysis, small sites can be combined.

There are three components of an AAP:

1. Written: This section contains generally boilerplate language that meets all regulatory requirements and includes the Minority/Female plan text and the Veterans/Disabled plan text.

2. Statistical: This analysis is done at the beginning of each plan year. It looks at a current "snapshot" of the workforce at each location and compares it to the recruitment pools (internal, local recruitment area and total recruitment area). The statistical analysis shows where the company is under-represented and provides goals based on this analysis.

3. Goal Attainment: This section examines the number of opportunities in each job group (hires plus promotions) and calculates percentages to determine if goals are met. All outreach efforts should be reviewed, documented and modified, if necessary.

Plan Implementation

Once the plans are developed, the company must develop an action-oriented program designed to achieve the identified affirmative action goals, including outreach and targeted recruiting strategies and mentoring, succession planning and career development.

Managers and supervisors should be trained on the AAPs, so that they clearly understand their responsibilities and areas of underrepresentation. Additionally, managers and supervisors should receive training on equal employment opportunities, hiring, sexual, and other forms of harassment and diversity.

Overview