For the first time in recent memory, the Office of Federal Contract Compliance Programs (OFCCP) has explained how it developed its first list of companies to audit in 2018 for affirmative action compliance. The agency cautioned that it may change its selection tactics in the future, and it has no legal obligation to share them. The OFCCP downloaded federal contract information from the Federal Procurement Data System–Next Generation (FPDS-NG), compared it to EEO-1 Reports, cleaned up the data, removed expired contracts and recently audited facilities, and selected 1,000 federal contractor establishments across the U.S. for review. Each local OFCCP district office is assigned a portion of the list, based on staffing levels.
As we previously reported, the OFCCP mailed “corporate scheduling announcement letters” (CSALs) to all 1,000 selected facilities on February 1, 2018, giving them a courtesy heads-up that an audit letter would eventually come their way. Then on March 19, 2018, local OFCCP district offices started at the top of their assigned lists and began mailing the actual audit scheduling letters. Compliance officers will work their way through their local lists during the coming months. According to the agency’s FAQs, the current list includes 515 companies, 83 corporate management compliance evaluations (CMCEs, or headquarters audits), 65 Functional Affirmative Action Plans (FAAPs), and 29 colleges and universities.
Tips For Federal Contractors: Among the 83 corporate headquarters selected for audit, at least 2 of those are Vigilant members. We expect at least one additional scheduling list, and perhaps more, to be generated later this year. As the OFCCP is gearing up to increase its compliance reviews, it is especially important for employers with federal contracts to stay current with their affirmative action obligations. Vigilant prepares written affirmative action plans for a reasonable annual fee. Questions about OFCCP audits? Contact us to learn more about our affirmative action services.