Friday, October 12, 2012

What Should Your Company Submit to OFCCP at the Start of a Compliance Review?

This article originally appeared in the October 2012 edition of the LocalJobNetwork "OFCCP Digest." 

Your company has received that dreaded letter from the U.S. Department of Labor's Office of Federal Contract Compliance Programs (OFCCP) indicating that your company has been scheduled for an affirmative action compliance review. After the initial panic has subsided, it is time to consider what you will send to OFCCP in order to comply with the requests in the scheduling letter and itemized listing you've received.

While more affirmative action compliance reviews by OFCCP are now ending in conciliation agreements than was the case in the past, there are still plenty of companies that are receiving letters of compliance at the end of their reviews. The decision on what items to send to OFCCP and what items to hold back can be crucial in determining the outcome of an affirmative action compliance review. The 30 days between the time the scheduling letter is received and the time that your company's affirmative action plan is due to OFCCP should be used to make various strategic and tactical choices on what to provide to OFCCP.