It’s that time of year again, the Office of Federal Contract Compliance Programs (OFCCP) has sent out its Corporate Scheduling Announcement Letters. This year however, the OFCCP discontinued its previous compliance evaluation strategy of Active Case Management (ACM) and rang in the new year with a new directive, Active Case Enforcement (ACE). The title alone should give you insight into the direction the OFCCP will be taking with audits this year.

Out with the Old

The old ACM strategy was focused on systemic discrimination and used an abbreviated desk audit process that closed reviews if there were no indicators of discrimination in groups of ten or more. A full desk audit was performed every 25th review and an onsite evaluation every 50th review. Here is what Patricia Shiu had to say about the old strategy: “While ACM has identified a number of systemic cases since its implementation, it has also caused OFCCP to