The Office of Federal Contract Compliance Programs (OFCCP) is vested with the responsibility to conduct periodic audits to prevent discriminatory employment practices on the part of federal contractors and subcontractors while recruiting, firing, transferring, promoting, and compensating their employees. To ensure you meet the requirements of the OFCCP, you should consider hiring OFCCP job posting services.
OFCCP audits can take different forms, but the COVID-19 pandemic pushed officers to shelve a number of them in order to adapt to the changing times. In early March 2021, the OFCCP declared that it would make amends to the 2020 Corporate Scheduling Announcement Letter (CSAL) list and temporarily remove all compliance job posting checks and reviews required by Section 503 and VEVRAA. Nonetheless, it’s important to understand all types of OFCCP audits.
Section 503 of the Rehabilitation Act of 1973 prohibits federal contractors and subcontractors from following discriminatory practices while employing individuals with disabilities. The section enforces affirmative action concerning such individuals. Due to the pandemic, this OFCCP audit was not a mandate as per the 2020 CSAL. But its requirements would come to play in upcoming cycles.
Functionally similar to Section 503, this type of OFCCP job posting audit focuses primarily on the Veterans via the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA). Due to the pandemic, this audit was not mandated by the 2020 CSAL. However, it certainly remains important.
A compliance check is a relatively low-maintenance OFCCP audit that demands little effort on your part. The 2020 CSAL did not make it a mandate for organizations, but it involves the following:
- Review records maintained by contractors and subcontractors and ensure they are consistent with Section 503, Executive Order 11246, and VEVRAA.
- Review of data of your present year plans and the results from the previous year
- Review of compliance job postings and instances of reasonable accommodation for people with disabilities
As an OFCCP audit, a compliance review involves thoroughly examining your existing written program and your long-term results. These reviews represent a major part of OFCCP audit, and they focus on a specific establishment or location. A compliance review involves a thorough analysis of a contractor’s employment practices, including the written AAP and the outcomes of their affirmative action efforts.
Functional Affirmative Action Program Evaluation (FAAP)
FAAP only applies to contractors and subcontractors with an approved Functional Affirmative Action Program agreement with the OFCCP. The length and complexity of these reviews will depend on the size of the FAAP in question. A FAAP evaluation is similar to compliance reviews. However, it only considers those employers who have been approved for the Functional Affirmative Action Program by the OFCCP.
Corporate Management Compliance Evaluation (CMCE)
Also called the “glass ceiling” audit, Corporate Management Compliance Evaluation (CMCE) is essential for organizations because it considers how people climb to senior roles. The focal point of this OFCCP audit is the feeder pools of your company, how people are transferred within your business, and their career advancement opportunities. The OFCCP officer pays more attention to components of a business’ employment process that ultimately affect the advancement or promotion of employees into mid- and senior-level roles.