This is the second in the two-part series Affirmative Action Plans: What You Need to Know. Last week we looked at ways to streamline the AAP development process. Today’s post will share tips to increase the likelihood of prevailing unscathed (or at least within tolerances) in the event of a government audit.
Audit Tips for Savvy Federal Contractor
The Office of Federal Contract Compliance Programs (OFCCP) has increased the number of audits it conducts by implementing shorter (sometimes as short as 15-20 minutes) audits called “desk audits.” If everything is satisfactory in a desk audit, the proceedings do not grow into a potentially more costly and time-consuming on-site or off-site audit. The goal of any organization is to provide the OFCCP with enough satisfactory information to get a representative to leave after the desk audit. To this end the following tips have been provided:
- Prepare a professional/professional-looking plan.
Although this may seem superficial, the number one way to increase your organization’s odds of ending the audit with the desk audit is to provide the OFCCP with a professional, and professional-looking, AAP. It shows the auditor that your organization takes its responsibilities seriously. It also helps if the plan itself is dust-free and appears to have been “used.”
- Analyze your data prior to the OFCCP.
Much like regularly scheduled check ups can help to protect against disease, regular evaluations of your organization’s hiring, promotional, termination, and compensation practices can help to avoid costly litigation and/or conciliation agreements. These types of analyses become even more important in tougher economic times when large class-action lawsuits proliferate due to lay-offs.
- Prepare an action plan for any/all audits.
If your organization has prepared a professional plan, ensured its data is accurate, and analyzed the data to know in advance what the OFCCP will see, then all that’s left is to develop an audit strategy. Should your organization adopt a hard stance? If the OFCCP presses a conciliation agreement, should your organization fight or would it be cheaper and easier to concede? What precedent is set if your organization concedes? These and many other considerations should be discussed prior to the audit.
As always, if you have any questions about the above OFCCP audit tips or the AAP development process, please let us know. Also, be sure to check out the affirmative action planning webinars and resources at www.BCGInstitute.org - our online HR EEO training community.