Federal Contractors to Be Audited for Affirmative Action Compliance

The Office of Federal Contract Compliance Programs (OFCCP) this month sent out 1,000 Corporate Scheduling Announcement Letters (“CSAL”), informing the recipients that their companies would be audited for compliance with affirmative action rules.

ofccp-to-audit-federal-contractorsThe letters are not formal audit announcements, but just a notification that the companies receiving them had been neutrally selected for auditing through the Federal Contractor Scheduling System.

Formal audit letters will be dispatched on March 19. Contractors will then have 30 days to supply the OFCCP with their Affirmative Action Program (“AAP”) and supporting documentation.

CSALs are not required by law, and thus even firms that did not receive one could receive a formal audit notification.

According to the OFCCP website, these are the requirements for an AAP:

When preparing AAPs, they should be customized to reflect an employer’s organizational structure, policies, practices, programs, and data. Usually separate AAPs are required for each establishment. In appropriate circumstances, an establishment may include several facilities located at two or more sites if the facilities are in the same labor market or recruiting area.

In addition to the records an employer is required to compile and maintain to support the AAPs [41 CFR 60-1.12, 60-2.17(d), 60-300.80, and 60-741.80]; the employer should also keep materials evidencing its affirmative action efforts. This may include items such as copies of collective bargaining agreements and other documents that indicate employment policies and practices; copies of letters sent to suppliers and vendors stating the EEO/affirmative action policy; copies of letters sent to recruitment sources and community organizations; and copies of contract language incorporating the regulatory equal opportunity clauses 41 CFR 60-1.4, 60-300.5, and 60-741.5.

SAMPLE AAP FOR DOWNLOADING


NOTE: The details in this blog are provided for informational purposes only. All answers are general in nature and do not constitute legal advice. If legal advice or other expert assistance is required, the services of a competent professional should be sought. The author specifically disclaims any and all liability arising directly or indirectly from the reliance on or use of this blog.
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