Actually, OFCCP will NOT ask for your most recent AAP during a compliance check. According to the compliance check letter that OFCCP has on file with the Office of Management and Budget, the agency will ask to see the following items: "1. AAP results for the preceding year (41 CFR §§ 60-1.12(b); 60-300.44(f)(4)and 300.80; 60-741.44(f)(4)and 741-80). 2. Examples of job advertisements, including listings with state employment services (41 CFR § 60-1.12(a), § 60-300.80, and § 60-741.80). 3. Examples of accommodations made for persons with disabilities (41 CFR § 60-1.12(a), § 60-300.80and § 60-741.80)." OFCCP has not done compliance checks for many years, and thus the process is also somewhat new to many at the agency. The current compliance check letter is different than the previous letter in that it asks for "AAP results for the preceding year" for all the laws enforced by the agency. In the past when OFCCP was doing compliance checks, the agency would have asked for a copy of an organization's goals progress report that is associated with its Executive Order 11246 affirmative action plan. A review of "AAP results for the preceding year" is likely to include a copy of the goals progress report, but it is also likely to include the assessment of outreach from the AAPs for individuals with disabilities and protected veterans. The compliance check is supposed to be an expedited form of compliance review. If you can provide satisfactory versions of the items above to OFCCP, that should end the review. You can see a copy of the compliance check letter at the following site: https://www.reginfo.gov/public/do/PRAViewIC?ref_nbr=201602-1250-001&icID=13735
You can 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. Or request a demo to streamline your compliance and recruiting efforts.