2B Determining the Need for an On-Site Review

When OFCCP schedules a contractor for a compliance evaluation, the compliance evaluation may consist of one or a combination of investigative procedures, including a compliance review, an off-site review of records, a focused review or a compliance check. Though the majority of compliance reviews do not involve going on site, on-site reviews are a part of each full compliance review and each focused review. COs determine whether to conduct an on-site review in conjunction with an off-site review of records or a compliance check, based on the circumstances of the evaluation and the outcome of the initial review.

Typically, the CO may determine to conduct an on-site review if the desk audit reveals indicators of discrimination. However, even if a desk audit initially reveals discrimination indicators, an on-site review may not be necessary. In a portion of compliance evaluations, potential discrimination indicators will be resolved after the desk audit concludes but before OFCCP conducts an on-site review, during the “pre-on-site.” One example of this is when the desk audit findings show that the required AAPs are acceptable, and then the contractor provides sufficient supplemental data during the pre-on-site stage to resolve desk audit discrimination indicators. In those cases, the CO may conclude the compliance evaluation after the desk audit with the approval of a supervisor. When sufficient explanation of any such disparities is not provided by the contractor, the CO must coordinate with the supervisor to prepare for an on-site review.