1I Summary of Acceptability Problems with AAPs and Itemized Listing Data

Investigators identify problems with the completeness and acceptability of a contractor’s AAPs under Executive Order 11246, Section 503 and VEVRAA, and Itemized Listing data in CMS. For each problem, Investigators must describe the specific problems and actions taken at the desk audit to resolve them, and actions planned for an on-site review. Any findings from on-site reviews are also recorded in CMS.

An Investigator may resolve some problems with the AAPs and Itemized Listing data at the desk audit after additional contact with the contractor. For example, if the Investigator cannot evaluate job group acceptability because there is no information on what job titles are in each group, that Investigator may be able to resolve the problem by obtaining the missing information from the contractor. The Investigator will note this follow-up contact and receipt of the additional information in CMS. Such a notation could be written like this: “Called J. Smith May 1, 2024 at 3:45pm and asked him to send a list of titles in each group. A second entry would note: “List of titles in each job group received May 8, 2024 via email.”

If an Investigator determines that an Executive Order, Section 503, or VEVRAA AAP does not meet one or more of the standards for acceptability as discussed previously in this chapter, the Investigator may review and analyze what was submitted by the contractor, but must consider the issuance of a SCN, as appropriate.