AAP audit

mushroomHR

Just received a certified letter yesterday from the OFCCP that our AAP is being audited. They want us to submit all kinds of information within 30 days. Since we're more than six months into our plan year we pretty much have to do a whole new plan from 1/1/04 to present. And they have the nerve to tell us that it should only take 4.5 hours to prepare a 4 page list of information they're requesting. What a pain in the a$$ this is. How have other government contractors felt about these audits? This is our first in 15 years. We had one right after I started working here and the company had NO information at all and no AAP. Since then, it got dumped on me and now I'm sweating. Thanks for listening.

cthr

Why do you have to do a new plan. Your current year plan should have been completed by 3/31 of this year.

mushroomHR

They said if we were more than six months into our plan year which started 1/1/04, we have to give them year-to-date information from 1/1/04 to 11/30/04. A whole new AAP will be done by 1/31/05 but they can't wait.

ritaanz

Hey Mush, not to worry. Even if your plan qualifies, they will still find something to grouse about. I had an audit sevaral years ago.

As I recall....The room next to my office had all the file cabinets. The weekend before the auditors arrived, a car had hit the building and drove into the file room. With all the debris and clutter, we could not get the door open for three days. I finally found the AAP and presented it to them. Two days later I was cited for a. not having the AAP available. (I was supposed to have made copies and kept them in different locations.) b. The pages were numbered incorrectly. (The page number was on the bottom and it was supposed to be on the top right corner.)

Go figure.

ray a

Two years ago this month I was audited, since it had been 5 months since my last AAP, I was able to submit that. They found a few red flags and accepted our explanations. I did find a math error which caused one of the red flags. I sent them documentation substantiating the error, and they were satisfied. It was interesting, our auditor was a minority himself - not sure if that had any bearing on the outcome.

Then last year, I our corporate office received the 'invitation' to be audited. Since they were past the 6 month point, they needed a new document. Their resident 'expert' who wrote the previous AAP was no longer there. I was next in line and had to spend a few days there helping them put it together. That audit included information on our wage plan implementation.

We passed both with flying colors. Be accurate and be honest. I found the auditors to be reasonable and cooperative.

jmcaa

I must be ignorant.....what is OFCCP and what is an AAP audit?

Thanks!

Whirlwind

Office of Federal Contract Compliance Programs and Affirmative Action Plan. Companies that hold federal contracts are required to have affirmative actions plans and OFCCP is the enforcer. I once had to have an affirmative action plan under a Texas law for state agencies, but fortunately I have had no first hand experience with OFCCP.

HRCalico

I'm a week late and way more than a dollar short, but I discovered today that Nebraska's OFCCP office provides technical support and assistance (for writing a plan, anyway). I got their contact info from the DOL/OFCCP's site. Not sure if Ohio does the same, but it might be worth a call to see if they can tell you any shortcuts or anything.

Don D

Since OFCCP is a federal, not state, entity, and part of the federal Department of Labor, they are all 'from the government and here to help you' on a nationwide, equal opportunity basis.

Having lived with them for 30 years from both the government and private industry employment sides of the coin, I can truthfully say that they are the most invasive and unneeded office of government in the entire spectrum of bureaucracy. I am frankly surprised the the current administration has not dismantled them.

Executive Order 11246 is just that, a presidential order. That order created the OFCCP and the morass that surrounds them. It was a huge dumptruck load of (call it what you will) on the heads of employers.

mushroomHR

You are absolutely right Don. It is the worst thing I have to deal with. Give me FMLA or ADA any day over the OFCCP and their affirmative action plans. I hope some they they are dismantled and only hope it's during my time in HR.