The new OFCCP audit letters under the American Recovery and Reinvestment Act of 2009 (ARRA) initiative have begun landing on the desks of contractors around the country. These letters are not your typical desk audit as they are giving notice to construction contractors that not only is the OFCCP is coming on-site, but they are only providing one-weeks notice.
A few items to pay attention to:
- Very short notice of an on-site visit
- The requirements of the letter are different than a typical desk audit
- The evaluation covers the past 6-months of activity
- There is no OMB number associated with the letter meaning it has not yet been approved by the Office of Management and Budget
- The letter can be directed to the President/CEO of the company
BCG also expects the standard Corporate Scheduling Announcement Letter (CSAL) and a new batch of desk-audit letters to be sent out in October of 2009. It is possible that desk-audits will be scaled back as much of OFCCP's current resources are focusing on ARRA audits.
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