OFCCP Audit
Checklist

HudsonMann Compliance Specialists have spent over 25 years successfully supporting clients through the twists and turns of OFCCP audits. Our checklist below shows you where to start – but for expert assistance, give us a call!

Download the OFCCP Audit Survival Guide

Your three (3) AAP Narratives plus:

  • Executive Order 11246 AAP
    • Organizational Profile
    • Formation of Job Groups
    • Statement of the percentage of minority & females
    • Minority & female availability
    • Comparison of incumbency to availability
    • Placement goals
  • Section 503 AAP
    • Evaluation of the effectiveness of outreach
    • Documentation of all actions taken to comply with Section 503 regulations
    • Documentation of the computations
    • Utilization Analysis of Individuals with Disabilities by job group
  • Section 4212 AAP
    • Evaluation of the effectiveness of outreach
    • Documentation of all actions taken to comply with VEVRAA regulations
    • Documentation of the computations
    • Documentation of hiring benchmark
  • Supporting Data
    • Copies of EEO-1 for 3 years
    • Copies of collective bargaining agreements
    • Copy of affirmative action goals
    • Data on employment activity
    • Compensation data
    • Copies of reasonable accommodation policies & logs
    • Assessment of personnel processes
    • Assessment of physical and mental qualifications
  • Also Required for Initial Submission
    • Any supporting documentation to show specific, targeted outreach efforts and action-oriented programs to meet unmet AAP goals
    • EEO Policy Statement indicating top US executive support
  • Required by Regulations – May Be Requested During Audit
    • Copies of listings with state employment service delivery system (ESDS)
    • Copy of online or newspaper ads showing EO tagline
    • List of places from which you recruit
    • Company overview
    • Purchase Order with affirmative action & Executive Order 13496/NLRA verbiage
    • Policies on maternity leave, FMLA leave, harassment
    • EEO is the Law Poster and Supplement for applicants and employees
    • Pay Transparency Policy Poster (E.O 13665)
    • E.O. 13496 Poster
    • Online Accessibility statement
    • VETS-4212 report for most recent year
  • Additionally, we recommend that the following also be in place before an OFCCP audit ever occurs
    • Designation of the person responsible for your Affirmative Action Programs
    • Problem Areas should be identified after review of utilization analysis, personnel activity and compensation systems
    • Action Oriented Programs specifically designed to meet placement goals or correct problem areas
    • Periodic internal audits performed to measure the effectiveness of your AAP. We recommend semi-annual reviews of all personnel activity.
    • Documentation to demonstrate compliance should be retrievable including contact with local associations serving minorities, women, individuals with disabilities and veterans
    • Ensure accessibility for individuals with disabilities: parking and entrance, restrooms, application computers/kiosks, workstations, etc.
    • Review EEO policy with all employees
    • Set up two files (work & personal) for all employees
    • Post EEO Policy statements
    • Applicant Flow Logs
    • Compensation analyses performed annually

Learn Even More about Affirmative Action Plans.

Affirmative Action Basics:

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Affirmative Action Essentials:

With over 4 hours of video-based learning, this course will help you master the essentials of Affirmative Action compliance at your pace. All content is mobile friendly so you can learn when and where it is most convenient.

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