Monday, December 13, 2010

Documentation is key to surviving OFCCP audit

Bond Schoeneck & King
Larry Malfitano
December 2 2010

Documentation of employment activities and workplace investigations is critical for all employers. Federal contractors subject to affirmative action compliance audits by the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (“OFCCP”) must be particularly diligent. The existence or absence of appropriate documentation during an OFCCP compliance audit often dictates the length and ultimate result of the audit.
Some of the records that are essential to the successful completion of an affirmative action audit are:
proof of listing all non-executive vacancies with the local office of the Department of Labor;
copies of outreach letters/e-mails to organizations showing efforts to attract qualified minorities, women, individuals with disabilities, and veterans;
applicant tracking data, identifying race, gender, position applied for, and disposition of all “applicants;”
identification by race and gender of hires, promotions, transfers, demotions, and terminations;
annual adverse impact analyses of personnel activities, including applicant/hires, promotions, transfers, demotions, and terminations;
annual analysis of compensation for potential disparities due to race and/or gender; and
copies of EEO-1 and VETS-100 filings for the prior three years.

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