Office of Federal Contract Compliance Programs

“Do not wait if you receive one of these, call Idaho Employment Law Solutions for help with your OFCCP audit, compliance and training.”
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The Office of Federal Contract Compliance Programs (OFCCP) is an agency within the Department of Labor with audit and enforcement authority for Executive Order 11246, Section 503 of the Rehabilitation Act of 1973, and the Vietnam Era Veterans Readjustment Assistance Act of 1974. The Executive Order and laws prohibit discrimination in employment and also require federal contractors and subcontractors to take "affirmative action" to address and eradicate any impediments to equal employment opportunity. Those business organizations who accepted funds under the Troubled Asset Relief Program (TARP) or subcontractors doing work for businesses who accepted TARP funds may, depending on the size of the business and TARP money involved, very likely come under the jurisdiction of the OFCCP and be subject to an audit. It is possible to survive an OFCCP audit if a contractor is prepared.

Idaho Employment Law Solutions, a minority law firm, was founded by R.A. (Ron) Coulter, the former Equal Employment Opportunity Manager for Boise Cascade Corporation. In the latter capacity, Ron was responsible for responding to, and coordinating all functions relevant to the OFCCP; and as a result, gained extensive experience in handling compliance evaluations of all types. Ron developed, managed, and was responsible for the corporate auditing of Boise’s establishments for EEO/OFCCP compliance. Ron was responsible for ensuring that all (124 ) affirmative action programs were completed and implemented in full compliance with all regulatory requirements including compensation analysis. Ron’s expertise allows Idaho Employment Law Solutions to provide the following services to its clients:

Organizational Coverage

Think you are not a federal contractor? You might want to know for sure as ignorance can be very costly. Federal affirmative action requirements apply not only to federal contractors, but also to the companies that serve as subcontractors to federal contractors. In fact, companies are bound to exactly the same requirements whether they sell military specified vehicles to the Department of Defense, or whether, as a subcontractor, they sell steel, employee uniforms, or office furniture to the vehicle maker, if the value of those goods or services is $50,000 or more and the subcontractor has at least 50 employees. Idaho Employment Law Solutions, can determine if you are a federal contractor and/or if you have jurisdictional defenses.

Affirmative Action Programs

Idaho Employment Law Solutions, a minority owned law firm, can develop a client’s AAP. Additionally, Idaho Employment Law Solutions, can teach the client to be self-sufficient in this area which will allow for the implementation and monitoring of the AAP in both the letter and the spirit of the law.

Internal Audits

In keeping with its preventative philosophy, Idaho Employment Law Solutions, can perform internal audits that will be in full compliance with 41 CFR 60-2.17(d). Idaho Employment Law Solutions, can also train the client’s internal staff to conduct periodic audits to identify problems and correct them before any scheduled compliance evaluation.

Compensation Analysis

In 2002, the OFCCP began to place significant emphasis in finding systemic discrimination in the contractor community. On June 16, 2006, the OFCCP's compensation analysis standards and voluntary guidelines were codified describing how both the OFCCP and federal government contractors will analyze compensation. On this same day, the OFCCP published its final voluntary guidelines for self-evaluation of compensation practices for compliance with Executive Order 11246 with respect to systemic compensation discrimination. Using the data provided by the employer, Idaho Employment Law Solutions, can conduct a compensation analysis and identify potential areas of concern in compliance with the new regulations.

Compliance Evaluation Support

The OFCCP monitors contractor compliance with regulations through compliance evaluations. There are several types of compliance evaluations; however, a contractor will be most affected by a desk-audit and a follow-up on-site compliance review. An on-site compliance review will be awarded to the contractor if the OFCCP determines, through it’s desk-audit review, that a further in depth review of the client’s establishment is warranted. Idaho Employment Law Solutions, can assist in the preparation of a desk-audit in a light most favorable to the contractor to avoid an on-site compliance review. If an on-site compliance review is awarded to a client, Idaho Employment Law Solutions, has the expertise and experience to prepare the client for the on-site and successfully guide the client through this detailed compliance evaluation. Idaho Employment Law Solutions, will represent the client during any phase of an OFCCP audit. As a minority owned law firm, Idaho Employment Law Solutions has the experience and expertise to negotiate conciliation agreements and defend the client in possible enforcement actions, if it becomes necessary.