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OFCCP Audit Key questions to assess your readiness The Office of Federal Contract and Compliance Programs (OFCCP) averages roughly 4000 audits per year. Is your organiza-tion ready? Can you relate to the many organizations that tend to quickly write their Affirmative Action Plans without securing time to clean the data and ensure accuracy? Then, when the audit notice arrives, there is a scramble to clean and submit the data. The list below highlights 15 key questions you need to address when preparing your plans and, most importantly, before your 30-day submission window closes: 1. Do you have the right people in the right plan as of the plan date? 2. Do you have your include/exclude employees distributed ap-propriately? 3. When looking at your workforce, is there a supervisor/manager in every department? If not, can you indicate where they sit in rela-tionship to their employees? 4. Do you have the correct positions in the correct job group? 5. Are your job groups too large? Too small? 6. Do all of the job groups contain positions with similar content, opportunities, and wages? 7. Have you reviewed your compensation? Can you appropriately explain any differences between any race and gender? 8. Did you have goals in the prior year? Did you attain those goals? If not, can you show efforts? 9. Are your historical transactions accurate? Are you showing any impact with your decisions? a. Verify that all hires were hired within the date range for the plan year. b. Make certain that all terminations are marked correctly (vol-untary or involuntary). c. Make certain that all transaction marked promotions are truly promotions and not transfers. Make sure that you know if these were competitive or non-competitive promotions. If they were competitive, can you identify the applicant pool if required? Do you have people promoted TO and FROM the same Job Title? Is this accurate? d. Review your applicant roster to make sure that all records from the Hire File are included as applicants in your applicant file and that they have been listed in the correct job group with the correct race and gender information. e. Ensure the applicant roster includes only those applicants who have met the basic qualifications and have not selected out/withdrew prior to an offer. Codes such as “does not meet basic qualifications,” “withdrew,” “Position Canceled” etc. have been removed from the analysis. f. Do you have all backup documentation to support your em-ployment decisions? 10. Have your open positions been listed with the state or local career centers? Can you show proof of listing? 11. Can you provide a list of all of your good faith efforts for women and minorities? 12. Can you show all of your engaged outreach and recruitment efforts for veterans and individuals with disabilities? 13. Have you evaluated your efforts to ensure they are effective? Do you have documentation to show your evaluation? 14. Have you communicated your plan results to management? 15. Have all of your managers been trained? Can you provide proof of training? This list highlights some of the critical items that you need to think about and review when writing your plans and/or preparing when the auditor comes knocking. The most important point to remember is don’t panic. Take your time, make sure everything is accurate, and be prepared to answer any questions that may arise. OSS By Rosemary Cox Rosemary Cox is Principal Business Consultant with PeopleFluent where she is a senior consulting resource for clients of all sizes regarding Affirmative Action planning, preparation, and compliance. She also conducts training and development courses, workshops and webinars at PeopleFluent for internal staff, existing clients, and potential clients. She has 18 years of experience in the fields of Affirmative Action Programs and compliance reporting. Visit www.peoplefluent.com Connect Rosemary Cox Follow @PeopleFluent Would like to Comment? Please Click Here. 6 Submit your Articles Talent Acquisition Excellence Essentials presented by HR.com | 12.2015


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