For those of you with calendar year AAPs, this month begins the mad dash to just get your AAPs completed, but I urge you to pause and take stock of the non-statistical elements of your AAP. The OFCCP has sent out the Corporate Scheduling Announcement Letters (CSALs) and this year you will see audits handled alittle differently. Active case management has been discontinued which means focusing solely on systemic discrimination is a thing of the past and the agency will be taking a deeper look at the AAPs submitted for desk audit.
Some of the things the OFCCP will have a renewed focus on are the Additional Required Elements required in Section 60-2.17:
Designation of Responsibility: Take this seriously, those who are named as having responsibility for oversight and implementati