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Run: OFCCP Affirmative Action Audit Readiness Checklist

Use this checklist to assemble OFCCP audit materials, verify AAP and pay data readiness, and track the 30-day response package before the scheduling letter d...

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Audit Scope and 30-Day Response Readiness

Record the date the OFCCP scheduling letter was received and the calculated response deadline.
Identify the establishment(s), plan year(s), and any functional or establishment-based AAP structure in scope.
Name the primary coordinator and backup responsible for assembling and submitting the response package.
Verify a tracker exists for requested items, source system, owner, status, and submission date.
Confirm audit files are stored in a restricted location with access limited to authorized personnel.
Identify the planned response method and any formatting or transmission requirements from the scheduling letter.

AAP Documents and Policy Governance

Confirm the current AAP is complete for each covered establishment or functional unit in scope.
Confirm prior-year AAPs are retained and can be produced if requested during the audit.
Verify the AAP includes required narrative sections, workforce analysis, and placement goals where applicable.
Confirm the EEO/AA policy is current, approved, and distributed to employees as required.
Capture the policy owner, approval date, and most recent review date.
Confirm any prior internal compliance findings, if applicable, have been reviewed and tracked to closure.

Applicant Flow, Hiring, and Selection Records

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

Compensation and Pay Data Readiness

Confirm a complete compensation extract can be produced for the requested period and employee population.
Verify the extract includes all required pay elements used in compensation analysis.
Confirm compensation records are mapped to the correct job titles, job groups, grades, and work locations.
Verify pay data is handled as confidential information with restricted access and secure transmission controls.
List any anomalies, missing fields, or exceptions that may affect the accuracy of the compensation submission.
Record when the compensation data extract was generated.

Supporting Evidence, Training, and Retention

Confirm training records for recruiters and hiring managers on EEO, selection, and documentation practices are available.
Verify retention requirements for AAPs, applicant flow logs, and compensation records are documented and followed.
Confirm prior OFCCP correspondence, internal findings, and corrective actions are retained in the audit file.
Verify files are named consistently and an index is available to help reviewers locate requested records quickly.
Describe any missing records or deficiencies and the corrective action owner and due date.
Inspector attestation that the audit readiness review was completed.

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