OFCCP Affirmative Action Audit Readiness Checklist

Inspection template for preparing federal contractor audit materials for an OFCCP scheduling letter response, including AAP documents, applicant flow logs, compensation data, and supporting evidence within the 30-day response window.

Audit Scope and 30-Day Response Readiness

• Scheduling letter received date and 30-day due date documented
  Record the date the OFCCP scheduling letter was received and the calculated response deadline.
• Covered establishment(s) and AAP year(s) identified
  Identify the establishment(s), plan year(s), and any functional or establishment-based AAP structure in scope.
• Response owner and backup assigned
  Name the primary coordinator and backup responsible for assembling and submitting the response package.
• Evidence inventory and document tracker created
  Verify a tracker exists for requested items, source system, owner, status, and submission date.
• Secure storage and access controls established for audit files
  Confirm audit files are stored in a restricted location with access limited to authorized personnel.
• Submission method and packaging requirements confirmed
  Identify the planned response method and any formatting or transmission requirements from the scheduling letter.

AAP Documents and Policy Governance

• Current AAP for each covered establishment available
  Confirm the current AAP is complete for each covered establishment or functional unit in scope.
• Prior-year AAP retained and retrievable
  Confirm prior-year AAPs are retained and can be produced if requested during the audit.
• AAP narrative, workforce analysis, and placement goals present
  Verify the AAP includes required narrative sections, workforce analysis, and placement goals where applicable.
• Equal employment opportunity and affirmative action policy current
  Confirm the EEO/AA policy is current, approved, and distributed to employees as required.
• Policy owner, approval date, and last review date documented
  Capture the policy owner, approval date, and most recent review date.
• Internal audit or self-assessment findings reviewed
  Confirm any prior internal compliance findings, if applicable, have been reviewed and tracked to closure.

Applicant Flow, Hiring, and Selection Records

• Applicant flow logs complete for the audit period
  Verify applicant flow logs include applicants, referrals, dispositions, and selection outcomes for the requested period.
• Job requisitions and posting records retained
  Confirm requisitions, job postings, and posting dates are available for the positions in scope.
• Selection criteria and interview notes retained
  Verify selection criteria, interview notes, and disposition reasons are documented and consistent with hiring decisions.
• Adverse impact or selection analysis available
  Confirm any required selection or adverse impact analysis is available for review.
• Applicant data fields are complete and standardized
  Rate the completeness and consistency of applicant data fields across systems used during the audit period.
• Applicant flow record count verified
  Enter the number of applicant records available for the audit period.

Compensation and Pay Data Readiness

• Compensation data extract available for audit period
  Confirm a complete compensation extract can be produced for the requested period and employee population.
• Compensation fields include base pay, bonuses, and allowances where applicable
  Verify the extract includes all required pay elements used in compensation analysis.
• Job title, job group, grade, and location mapping validated
  Confirm compensation records are mapped to the correct job titles, job groups, grades, and work locations.
• Compensation data access restricted and transmission secured
  Verify pay data is handled as confidential information with restricted access and secure transmission controls.
• Known pay data anomalies documented
  List any anomalies, missing fields, or exceptions that may affect the accuracy of the compensation submission.
• Compensation extract timestamp recorded
  Record when the compensation data extract was generated.

Supporting Evidence, Training, and Retention

• Recruiter and hiring manager training records available
  Confirm training records for recruiters and hiring managers on EEO, selection, and documentation practices are available.
• Record retention schedule covers OFCCP materials
  Verify retention requirements for AAPs, applicant flow logs, and compensation records are documented and followed.
• Prior correspondence and corrective actions retained
  Confirm prior OFCCP correspondence, internal findings, and corrective actions are retained in the audit file.
• Document index and file naming convention standardized
  Verify files are named consistently and an index is available to help reviewers locate requested records quickly.
• Outstanding gaps assigned corrective actions
  Describe any missing records or deficiencies and the corrective action owner and due date.
• Inspector sign-off
  Inspector attestation that the audit readiness review was completed.