The OFCCP has hit the ground running with their new American Recovery and Reinvestment Act of 2009 (ARRA) audit efforts. Many contractors are now receiving audit letters with specific needs under the ARRA initiative. Construction contractors are being asked for significant material under the ARRA audit format and Service and Supply contractors are receiving new letters as well. One difference we are seeing is that the Service and Supply contractors are receiving a standard desk audit letter with an additional letter stating that they were selected under the ARRA initiative. The desk audit letter for Service and Supply does not suggest that the OFCCP will conduct an automatic on-site review which conflicts with the defined structure of the ARRA plan so we will post updates as the audits progress.
An additional measure BCG has seen the OFCCP take is that the Compliance Officers are taking an extremely aggressive approach to collecting additional data/information during the audit. We are seeing OFCCP ask for responses to data requests within the same day (by Close of Business was the term used) and threatening to turn a desk audit into an on-site audit if the contractor does not comply. We have also seen OFCCP inform a contractor that the ARRA driven on-site audit would commence within less than one weeks notice. It is the belief of the BCG staff that these demands are related to the comments heard at National Industry Liaison Group where OFCCP stated that they were not pleased with the amount of resistance they were seeing to additional information requests. Also, OFCCP has a mandate to complete 450 ARRA audits by September 30, 2010.
Please see recent Blog posts and register for our free webinars at www.bcginstitute.org for all of the latest information on ARRA audits and OFCCP initiatives.
Subscribe to:
Post Comments (Atom)
Posts
No comments:
Post a Comment