We are an employer with offices across the country (and a establishment based AAP program). We have some larger offices and many smaller offices with less than 50 employees. Unfortunately, the smaller offices don’t logically “roll up” into other plans in their region (through a common supervisor or other mechanism). Is there a risk in pooling all our small offices in one region together and creating a “small office plan” for that region (with no larger office included)? What are the best practices for handling smaller offices given the OFCCP’s most recent practices around AAP certification and audit selection?
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