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Use this OFCCP audit checklist to ensure you’re doing what is required to maintain OFCCP’s regulations including VEVRAA, Section 503, and EO 11246.

Each year the Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) selects numerous federal contractor establishments to evaluate their compliance with affirmative action regulations. While audit preparation is mandatory, if you have the appropriate documentation on hand you can make the process easier to coordinate.

If you have been selected for a desk audit, you will receive a notification via a scheduling letter from the OFCCP, which is known as the “desk audit” process for compliance. From receipt of this letter forward, you will have 30 days to provide the agency with documentation including a copy of your affirmative action plans and supporting data for all employee compensation.

Once you submit your documentation, the office will analyze the data and make subsequent requests for additional information, as necessary. You will need to respond to all requests in a timely manner and be prepared to address any follow–up questions should they arise.

As the agency conducts their desk audit, they will determine if an on–site audit review is required. This assessment is based on how you respond to their initial request, including the delivery of all the itemized listing of materials that has been outlined in the scheduling letter. In its initial review of data, the OFCCP is looking for any indicators of potential discrimination.

At this point, two scenarios can play out:

  1. On the basis of information the agency receives, the desk audit will be closed and you will receive a letter indicating that no violations were present. Once audited, you will not be open to another audit for two years.
  2. You will receive a notification of any potential discriminatory practices, which will be followed by the on–site review process. During the on–site review the OFCCP will conduct a more detailed analysis, and may ask for additional compensation data, personnel files, and other policies and procedures. This may also include conducting interviews with hiring managers and other staff members.

During the on–site review, it will be determined if the contractor is in fact implementing an effective affirmative action plan and complying with equal employment opportunity guidelines.

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To ensure that you are always prepared to be audited, be sure to meet OFCCP regulations, including reaching diversity candidates and documentation.

OFCCP compliance requires that job vacancy announcements reach state employment agencies, and in turn qualified applicants representing minorities, veterans, women and people with disabilities. As outlined by the OFCCP, federal contractors need to prove that they are actively working with state career sites, posting jobs and keeping records of applicants relative to minority or veteran status.

Preparing hiring data for reporting regulations is an important aspect of the compliance process. It is imperative that employers proactively maintain data on job postings and have this data available for submission should they be required to do so during an audit, and on an annual basis. The collection, storage and reporting of online job applicant data is a key mandate to meet OFCCP compliance, and specifically a requirement necessary should you be approached to participate in a desk audit.

For more information on OFCCP compliance, visit our OFCCP compliance resources.

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Stevens Tate

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