OFCCP Game Plan for ARRA Audits

As mentioned in a previous Blog, the OFCCP has rolled out their new ARRA audit letters and contractors are feeling the heat, especially construction contractors. The OFCCP is sending out the new audit letters with additional requirements that affect construction contractors and their subcontractors.

It can be helpful to know what the OFCCP's strategy is, and fortunately they have provided some information on their website under the following link:

http://www.dol.gov/esa/ofccp/OFCCPRecoveryActPlan.htm

A few highlights:

1. Conduct 450 ARRA driven reviews
2. Only 90 of which will be service and supply
3. 10% of the audits will be for new contractors
4. 360 of the 450 or 80% of the audits will be for construction contractors
5. Completion of all audits by September, 30, 2010
6. Conduct 150 reviews each quarter starting in Q3, 2009
7. OFCCP will host 120 compliance events including seminars and webinars
8. Prior to an award of $10 million or more, OFCCP will need to receive pre-award clearance request from the potential contractor
9. OFCCP will use an internal monitoring system to ensure that audit goals are met
10. Lorenzo Harrison of the national OFCCP office is the lead for monitoring the ARRA audit nationwide directive

Biddle Consulting Group is actively involved in supporting new ARRA driven audits. We will post information on the OFCCPs activities as they progress.