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AAP Basics
The Audit Process People
The Big Picture
The AAP Plan
Creating and Implementing a Plan
The Audit Process
30 day notice letter
Types of evaluations
Typical questions
Typical contractor pitfalls
How to be prepared
 
1. 30 day notice letter
If you are selected for a compliance evaluation (audit), you will receive a letter from your OFFCP district office requesting you to deliver a copy of your 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 your facility. There are other types of evaluations which can be used by the OFFCP to review contractor compliance with the AAP regulations.
 
2. Types of Evaluations
 
OFCCP
Compliance Checks
Focused Reviews
Desk Audits Only
Complete Compliance Evaluations (audits)
Corporate Management Reviews
Other combinations of the above
EEOC/DFEH
Intake Process
Employer Information
Investigation
    Mediation
    Right to Sue
    Formal Charges of Discrimination
3. 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 resume in each personnel file?
Do manager's Performance Evaluations include comments about EEO AAP efforts?
Do employment ads include an EEO statement?
Are vendors and subcontractors notified of EEO policy/ (you will need to produce supporting documentation)
Pictures/ads of minorities, women, individuals with disabilities as well as men and non-minorities shown?
 
Some questions you may be asked
Is there a self-identification tear-off or attachment on your job applications?
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? When?
How long are applications and resumes kept?
Are pre-employment physicals given? Under what conditions?
 
Describe the application or resume retrieval process
Describe the organization's application & record keeping process. Is it documented?
Who is responsible? How is information maintained?
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 the company employee groups encouraged to refer minority, women, veterans, disabled individuals?
 
4. Pitfalls
If any of the following is true for your company, your 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
5. How to be prepared
Prepare a strategy to win each audit
Clean-up inaccurate and incomplete data records
Prepare your Senior Management team as well as other managers for the audit
Consider using a 'Mock Audit' to practice
Know your auditor's time frame


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