1. Ensure compliant HR processes: Federal contractors should provide thorough training and conduct internal audits to ensure their HR processes are compliant, discourage discrimination, properly documented, and applied consistently. HR processes to monitor include:
    • Applicant tracking and recordkeeping
    • Hiring, promotions, and terminations and recordkeeping
    • Compensation
  2. Use employee and applicant data for required reports and complete affirmative action plans within 60 days of the start of the plan year.
  3. Review completed affirmative action plans with internal stakeholders (executives, hiring managers, recruiters, etc.) and create action-oriented programs to control risk and increase diversity. Specifically:
    • Review and investigate areas of adverse impact, lack of applicant pools, and unmet affirmative action goals
    • Review proper documentation to address potential risk and support good faith efforts
    • Respond to areas of risk within plans
  4. Analyze compensation programs annually for internal equity and make adjustments as necessary. Review best practices for compensation analysis and implement corrective actions to be “audit ready” for potential OFCCP compensation reviews.
  5. Provide essential affirmative action training to HR and other stakeholders involved in employment decisions, including recruiters and frontline managers.
    • Provide training to new stakeholders as part of the onboarding process, and annually to all stakeholders
    • Integrate training with internal Learning Management System
    • Encourage attendance at webinars and other educational opportunities throughout the year
  6. Align EEO-1 reporting with affirmative action reporting
    • Each physical location from the employee data, and in existence during the EEO-1 reporting period, should have a separate EEO-1 report
    • Each location with over 50 or more employees should have its own AAP
  7. A detailed list of other OFCCP requirements to implement and monitor can be found in our Compliance Checklist.


By meeting these objectives the Federal Contractor will have an affirmative action program that complies with OFCCP regulations and meets the spirit of Executive Order 11246, Section 503 of the Rehabilitation Act, and the Vietnam Era Veterans Readjustment Assistance Act. Federal Contractor would expect a very high success rate in OFCCP compliance reviews. Potential financial liability and loss of any federal contracts would be minimized. Affirmative action compliance on state and municipal level would be enhanced. Federal Contractor attempts at future federal, state, and municipal contracts that require AAPs would be made easier.