OFCCP Audit Services

Up-to-date knowledge and support during

OFCCP is the lead Agency in the Department of Labor responsible for the enforcement of affirmative action program requirements. These Compliance Evaluations (audits) can be intense and time-consuming for federal contractors. Gerstco consultants possess up-to-date skills and information concerning Compliance Reviews and can provide broad audit services ranging from the development of submission documents (formal affirmative action plans) to interfacing with Agency Compliance Officers and briefing managers and employees for interviews during the on-site portion of the audit.

Audit Types

Many OFCCP Compliance Evaluations are Desk Audits where  contractors submit Affirmative Action Plans for formal review by an OFCCP Compliance Officer. The AAP review may take some time and eventually the audit concludes with a close-out letter indicating no violations, or a Letter of Violations will be issued, indicating the contractor must enter into negotiations to address the issues found. Gerstco’s initial audit services will include update/development of a technically-compliant affirmative action plan, and briefings with HR, Legal, and Sr. Managers regarding the compliance-readiness of the contractor.

OFCCP may schedule an On-Site Review when issues are found at the Desk Audit stage and they are not resolved for whatever reason. The contractor will be notified by OFCCP of their intent to come on-site and Gerstco’s audit services will include an assessment of the contractor’s readiness for this next audit phase, including a Facilities Check, Management Briefings, and the preparation of additional requested materials. Gerstco will provide a Senior Compliance Specialist to be at the facilities during this time to work with HR and assist with special projects and other data requests.

A Corporate Management Review (CMR) is a Compliance Evaluation at the Headquarters Offices of a federal contractor. This type of review contains all the characteristics of a Regular Compliance Evaluation, with the addition of the focus by OFCCP at Senior Management-Level positions. Gerstco’s services will include an in-depth review of the top positions in the Company with regard to the participation of minorities and females. A Desk Audit and On-Site review are standard phases of a CMR. Gerstco’s Sr. Staff can provide materials to brief Sr. Managers and other managers, and can work with the contractor’s legal team, if requested.

A Functional AAP Compliance Evaluation includes all the attributes of a Regular Compliance Evaluation; however, the focus of OFCCP is to audit a specific line of business for affirmative action program compliance. This includes the audit of an Affirmative Action Plan that is non-location-based. Gerstco’s services include the preparation and update of the FAAP (Functional Affirmative Action Plan) and a review with Legal, HR, and Sr. Management, regarding the compliance readiness of the organization. A Desk Audit and an On-Site review may be done in this type of audit, using one of the facilities listed in the FAAP.

A Job-Site audit is a particular type of compliance audit reviewing specific jobs or job situations of a federal contractor. The OFCCP will notify the contractor of their intent to inspect the affirmative action plan and review the facilities and job site involved. Gerstco’s services include a Facilities Check and an in-depth review of the job situation involved in this type of Compliance Evaluation.

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