The following elements should be in place in preparation for an OFCCP Compliance Evaluation:

  • A current and previous year’s affirmative action plan for Minorities and Women, Individuals with Disabilities, and Veterans with all required analysis. If you are six months or more into your AAP plan year then goals and activity analysis should be updated.
  • Designation of the person responsible for your Affirmative Action Program
  • Review areas of underutilization for Minorities, Females, Veterans, and Individuals with Disabilities and document good faith recruiting efforts in these areas
  • Review and address any areas of adverse impact in new hire, termination or promotion activity
  • Document effectiveness of outreach for Individuals with Disabilities and Veteran recruiting
  • Document audit and reporting requirements for Individuals with Disabilities and Veteran AAPs
  • Review and document physical and mental job requirements yearly
  • EEO-1 Reports (3 years) and VETS 4212
  • Perform compensation analysis to ensure compliance with Equal Pay regulations
  • List jobs with appropriate Employment Service Delivery System. Appropriate systems include local employment service offices and state workforce agency job banks
  • Ensure Accessibility for individuals with disabilities: online applications, parking and entrance, restrooms, application computers/kiosks
  • Disability accommodation policies and logs
  • EEO is the Law” poster for applicants and employees and “EEO is the Law Supplement
  • Post Pay Transparency policy in meeting areas and to be accessible by applicants  (EO 13665)
  • Post EEO Policy statements in meeting areas and online to be accessible by applicants
  • E.O. 13496 poster (employee rights under Federal labor laws)
  • Ensure EO clause on purchase orders and subcontracts
  • Provide written notice of AAP obligations to subcontractors
  • Notify labor organizations with which you have a collective bargaining agreement of non-discrimination obligations.