OFCCP Corporate Management Review Initiative Defined in New Budget Plan

The OFCCP has unveiled a new budget plan that defines their goals for 2010-2011 and initiatives that could have a tremendous impact on larger organizations. In the excerpt below, OFCCP is stating they plan to conduct multiple establishment reviews of single organizations that will span a two-year time period. The premise being that OFCCP wants to determine how a series of reviews for one organization in one-year will impact compliance reviews for the same organization in the second year. Making this initiative even more eye-catching is that the OFCCP has indicated the reviews will cover multiple, randomly selected sites in the first year and a different set of locations in year two to determine the impact of the first series of audits.

A critical question that is not addressed is if the organization will be forewarned of these audits. It will also be interesting to see if the contractor community will claim that this new format is burdensome.

Quoted from the OFCCP FY 2011 CONGRESSIONAL BUDGET JUSTIFICATION:

OFCCP will also conduct a corporate, multi-establishment compliance evaluation approach designed to assess whether OFCCP’s activities within a single corporation leads to increased compliance by the other establishments within the same corporation. Using the Corporate Management Compliance Evaluation list, which uses neutral selection criteria, OFCCP will identify the first eligible corporation on each regional list for a multi-establishment corporate-wide review. A random sample of establishments from each corporation will be drawn for compliance evaluations. One half of the establishments will be scheduled for compliance review in FY 2010; the second half of establishments will be scheduled in FY 2011. Using this approach, OFCCP will measure whether subsequent evaluations result in a higher compliance rate than those of the first group, indicating that OFCCP has had some impact on corporate practice.