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Affirmative Action Planning

Get the ‘Big Picture’ about Regulations and Compliance


The Audit Process

30 day notice letter

If the company is selected for a compliance evaluation (audit), the OFCCP district office will send a letter requesting the delivery of a copy of the Affirmative Action Plan within 30 days. (See the Plan Basics and What is an AAP to review the specific components). This is reviewed at the OFCCP office as part of a desk audit, and is followed by an on-site review at the facility. There are other types of evaluations which can be used by the OFFCP to review contractor compliance with the AAP regulations.

Types of Evaluations


Typical Questions

There are several components to the compliance evaluation visit, including direct observation, indirect observation, and questions. Here are some of the things auditors may look for:

  • Is the employment application process physically accessible?
  • Are EEO AAP posters or notices posted in the lobby, interview areas, on bulletin boards? Are they visible in every building?
  • Is there an application or a resume in each personnel file?
  • Do manager’s Performance Evaluations include comments about EEO AAP efforts?
  • Do employment ads include as EEO statement?
  • Are vendors and subcontractors notified of EEO policy?
  • Do company ads and literature include minorities and women as well as men and non-minorities?
  • Is there an area on the job application where job seekers can self-identify?
  • Is a Post Offer Self-Identification form sent to all individuals?
  • How are applicants who apply for the same positions tracked?
  • Have interviewers had training in EEO and interviewing?
  • Are pre-employment physicals given? Under what conditions?
  • How long are applications and resumes kept?
  • Describe the organization’s application & record keeping process. Is it documented?
  • How is documentation on employees provided?
  • Is there information on training courses taken by employees and can it be retrieved for the AAP?
  • Describe the Company’s Job Accommodation Process.
  • Are company employee groups encouraged to refer minority, women, veterans, disabled individuals?


If any of the following is true for the company, the AAP may have problem areas.

  • Lack of management commitment
  • Failure to conduct necessary self-audits
  • Absence of consistent policies and guidelines
  • Ineffective employment application procedures
  • Lack of harassment-prevention programs
  • Lack of review for key employment actions
  • Failure to listen to internal (diversity) groups

How to be Prepared

  • Prepare a strategy to successfully complete each audit
  • Clean-up inaccurate and incomplete data records
  • Prepare the Senior Management team as well as other managers for the audit
  • Consider using a “Mock Audit” to practice
  • Know the auditor’s time frame