The OFCCP website has a lot of good information — but, maybe too much information. It could take days to find exactly what you are looking for. Here we provide some of the more sought after or hard to find OFCCP data and information.
In addition to the blizzard of laws and regulations that accompany workplace affirmative action, the OFCCP also publishes many other documents that can be useful to those responsible for compliance within a government contracting company. Some of the documents are meant for the Agency’s own internal use in training new compliance officers or explaining the Agency’s position on confusing areas in the practice of affirmative action (a Policy about not guessing an applicant’s gender, race, ethnicity for example). Other OFCCP documents are written specifically for different contractor communities — like the AAP for “small” companies (< 150 employees) and the “Technical Assistance Guide for Federal Supply and Service Contractors.”
- An Analysis of Reasons for the Disparity in Wages Between Men and Women
“this study leads to the unambiguous conclusion that the differences in the compensation of men and women are the result of a multitude of factors and that the raw wage gap should not be used as the basis to justify corrective action.”
- Audit Scheduling Letter
It is always nice to have a heads-up on what you will need to provide the OFCCP in case of an untimely audit request. Above is the Audit Scheduling Letter your company would receive at the start of a regular OFCCP audit. The OFCCP has two other types of audits: Section 503 Focused Review and VEVRAA Focused Review.
- Federal Contract Compliance Manual (FCCM)
This manual is used internally at the OFCCP to train compliance officers. It was updated in October of 2014 and is an excellent reference for what will be analyzed and checked during a Compliance Review.
- New Contractors’ Guide
The OFCCP has developed the New Contractors’ Resource Guide to introduce new contractors to their EEO obligations and the enforcement process.
- Sample AAP — OFCCP’s Version
Caveat: This sample may be ok for a small employer of less than 150 employees because it portrays job groups and EEO-1 categories as the same thing. They are not the same. For larger (or small complex) companies, a great deal more care should be taken in developing your job groups. EEO-1 categories are government defined groupings. Job groups are company defined groupings. Also, the sample text in many cases provides commitments which are above and beyond that which is required by the actual regulations. A minimalist approach to developing your company’s AAP document is probably better. AAPs become the property of the federal government when requested by the OFCCP for an audit. And, the OFCCP cannot guarantee that the contents of your AAP will not be released to the public under a Freedom of Information Act (FOIA) request. For this and other reasons, it is probably not wise — nor required — to put your “Support Data” within your actual AAP document as this sample suggests.