1Q Summary of Potential Discrimination Areas and On-Site Investigative Plan (All Laws)

All potential discrimination problems that an Investigator identifies during the desk audit must be summarized, as appropriate, in CMS. These summaries must include any problems the Investigator identifies while reviewing compliance history, the contractor’s AAPs, and any problems the Investigator identifies during the review and analyses of Itemized Listing data.

For each potential discrimination problem an Investigator identifies a plan of action must be developed. If the problem(s) are not resolved before the on-site phase of the evaluation, the Investigator should include the problem(s) in an on-site investigative plan (On-Site Plan). The On-Site Plan should be as specific as possible and will set priorities for the overall investigation, documents to be gathered, and potential interviews. The On-Site Plan should include verification of the contractor’s implementation of certain equal opportunity clause requirements (e.g., posting current required EEO notices), implementation of the regulations prohibiting discrimination on the basis of sex at 41 CFR part 60-20, and implementation of the guidelines on discrimination because of religion or national origin at 41 CFR part 60-50. The Investigator will record the on-site review findings for any potential systemic or individual discrimination that was identified during the desk audit or discovered during the on-site review. These findings must include a discussion of the nature of the problem(s), relevant evidence collected and reviewed, actions (if any) taken to resolve the problem, and whether and how the problem was resolved. Additional information regarding the on-site review is discussed in Chapter 2.