Are You Due for an OFCCP Audit?
The Office of Federal Contract Compliance Programs (OFCCP) just posted its list of companies that are scheduled for an audit of their affirmative action programs here: https://www.dol.gov/agencies/ofccp/foia/library (click on the FY 2020 CSAL links). This is essentially a heads-up from the OFCCP that the contractors listed should be prepared to receive formal notice of an audit. If you find yourself on this list, it is important to proactively get your business in order for an audit to see a smoother and more successful audit process. There are now several different types of audits, so even companies that have been audited in the past might be selected for a new type of audit that they have never experienced.
Stinson regularly advises government contractors in preparing affirmative action plans as well as defending OFCCP audits. Contact the authors if you have any questions about this article, affirmative action plans, OFCCP audits, pre-audit compliance reviews, or OFCCP audit defense. If you are not on this list, it doesn’t mean that you are not considered a government contractor or subcontractor subject to OFCCP oversight, audit, or investigation. OFCCP can initiate an audit without putting a contractor on the CSAL list. If you have questions about your status as a government contractor, or audit-readiness in general, please contact the authors or the co-chairs of Stinson’s Government Contracts & Investigations Practice Group.