It’s never a happy day when your company receives a letter from the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) informing you that your company will be undergoing an affirmative action compliance review. However, there are some common mistakes that companies make at the start of a compliance review that can have major implications for how the review will close. We’re going to use this article to outline some of these mistakes.
For those readers who have never been through an OFCCP compliance review, the process begins when the agency sends what it refers to as a “scheduling letter” to a company. The scheduling letter informs the company which location will be undergoing the compliance review and gives the company 30 days to submit certain information. An itemized listing is attached to the scheduling letter, and the itemized listing has 22 separate items that must be part of the submission to OFCCP. Until October of 2014, the itemized listing only included 11 items, but it was subsequently changed in