It is the Tuesday after a long holiday weekend, and you are faithfully going through the pile of mail on your desk when you spy an envelope from the United States Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP). You open the envelope and, sure enough, your facility has been selected for a compliance review under Executive Order 11246, the Vietnam Era Veterans’ Readjustment Assistance Act, and Section 503 of the Rehabilitation Act. Which of the following most accurately describes your response?
A. Hot dog! I finally get to do something with those affirmative action plans I have been patiently preparing for years!
B. Story of my life . . . any time I take a long weekend, I always return to bad news.
C. An OFCCP audit? Someone turn off the lights so I can curl up and cry in the corner.
Regardless of which response you chose, before you respond to the OFCCP, there are several things you should do to increase your chances of a successful audit outcome:
Given the aggressive nature of the OFCCP’s current enforcement agenda and efforts, it is often the little things that matter the most. Errors in data, a lack of records, or a failure to review and understand the information in the company’s AAPs can create substantial problems during an audit and may result in significant legal liability for a company.