OFCCP Has Reverted to Previous Audit Enforcement Methods

Under new directives, the OFCCP (Office of Federal Contract Compliance Programs) is eliminating Audit Submission Deadlines in all but “Extraordinary Circumstances.”

Under previous direction, you could request and receive extra time to prepare AAP data for submission. Those days are now gone. 


The OFCCP will continue to issue CSAL (Corporate Scheduling Announcement List) and disclose selection method; however, it will no longer wait 45 days after the posting of the list to start scheduling the audits. Those scheduled for the audit shortly after the CSAL list is published will not receive the benefit of more time to prepare.


Another change is that the OFCCP may now directly contact and interview employees without the contractor being involved in the scheduling process. According to the OFCCP, this ensures that witnesses are comfortable in communicating with OFCCP without being afraid of reprisal. OFCCP will request that contractors provide the agency with unredacted contact information such as phone numbers, email addresses, and mailing addresses.

How can C2 Essentials help?

C2 helps and advises our clients on how to remain in compliance and avoid costly, time-consuming audits. We pride ourselves in being meticulous and thorough, and we maintain all of the data necessary for you to be in compliance and successfully pass the audit.  These records include:

  • Applicant tracking
  • Invitation to self-identify
  • Equal Employment Opportunity Commission compliance
  • Termination assistance
  • Annual Affirmative Action Plan
  • Compensation and incentive plans