The Benefits of a Conducting an On-Site Mock Audit

Why should a federal contractor consider an onsite mock audit? With the current OFCCP administration, we have seen compliance officers who conduct onsite audits regardless of whether potential problem indicators exist or not (in fact, Active Case Management is no longer being practiced by the OFCCP). In several audits and separate local ILG meetings, OFCCP representatives had also stated that on-site audits are now part of OFCCP’s standard practice. So, how can an employer get better prepared for the inevitable on-site visit from a compliance officer in case of an audit? Let’s evaluate the benefits of conducting an “onsite mock audit”.

An on-site mock audit is a dry-run of the actual OFCCP on-site visit (of course, without the presence of the OFCCP Compliance Officer). In an on-site mock audit, employers need to anticipate the scenarios and questions that they think might occur during the actual on-site audit.

Following are some common scenarios during an on-site audit. Each scenario is followed by reason(s) why conducting mock audit prior to the OFCCP’s actual visit date will prove beneficial:

1. The compliance officer will tour the facility – the mock audit can reveal potential deficiencies in, but not limited to, the following areas:
o Required posters are not posted in conspicuous places (e.g., common areas)
o Areas that are not accessible to employees/applicants with mobility impairments
o Unpleasant and/or hazardous work conditions
o Employees not exercising safety measures set forth by the organization

2. The compliance officer will hold formal and informal interviews with employees and HR Managers – the mock audit can reveal deficiencies in, but not limited to, the following areas:
o Some employees are not aware of the employer’s sexual harassment policies
o Some employees are not aware of the measures set by the organization to ensure safety while performing the necessary work
o Employees and managers are not aware of the terms EEO or AA
o Managers are not aware of the affirmative action programs

3. The compliance officer will review personnel data and supporting documentation with regards to some personnel decisions - the mock audit can reveal deficiencies in, but not limited to, the following areas:
o Lack of or insufficient data (e.g., are all the hires in the applicant file, record-retention obligations, etc.)
o Lack of or insufficient documentation to support personnel decisions
o Lack of proper documentation (or disposition) on who were considered as applicants
o List of employees who self identified as veterans or with disability

4. The compliance officer will review outreach programs - the mock audit can reveal deficiencies in, but not limited to, the following areas:
o Lack of proper documentation on the outreach programs (who or which organization were contacted? What are the results of such programs? etc.)
o Did the outreach programs prove to be effective?

These are just some of the things that can help an organization be prepared for that “on-site day.” Being well prepared for the on-site can minimize any anxieties that the executives, managers, supervisors, and employees may have regarding the visit. A mock audit can also foster confidence which should minimize inconsistent responses to the compliance officer and hopefully, result in a less “painful” visit.