OFCCP to Begin Checking Breadth of Affirmative Action Programs

December 07, 2018

Beginning in 2019, the U.S. Department of Labor's Office of Federal Contract Compliance Program (OFCCP) will be checking how federal contractors have answered one question asked by the Office to determine whether the agency should schedule a compliance audit.

Increased likelihood of an audit: If a federal contractor has checked the box in the OFCCP's System for Awards Management (SAM) system that “it has not developed and does not have on file, at each establishment,” an affirmative action program, OFCCP will schedule the contractor for an audit.  This will take place even if the box was checked by mistake.

Decreased likelihood of an audit: If a federal contractor has checked the box in the SAM system that “it has developed and has on file, at each establishment,” an affirmative action program, OFCCP is far less likely to schedule the contractor for an audit.

Takeaway: Federal contractors should review their information in the SAM system to make sure their procurement and contracting personnel have submitted the correct information and ensure that they have an affirmative action program on file at each establishment.