DCI has recently seen an increase of audit “pre-requests,” in which a compliance officer requests that a contractor submit additional items to those found in the Itemized Listing. This request is made by OFCCP prior to receiving the contractor’s desk audit submission and asks for items that often appear in an early post-submission request, such as job listing evidence, copy of VETS reporting, copy of employee handbook, etc. It’s unclear whether these requests are consistently asked of all contractors audited through particular district offices; however DCI has seen some consistency of items in such requests.
There are some concerning aspects to these “pre-requests,” including the following points:
Because these “pre-requests” appear to be increasing in frequency, contractors are advised that if they receive such a request for an establishment, begin by engaging with the compliance officer. Outright denying access to requested materials is not recommended; however, DCI does recommend acknowledging receipt. Contractors should work with the compliance officer to determine a different submission date and/or politely request that OFCCP first review the desk audit package once delivered, before requesting items that are not a part of the OMB-approved scheduling letter and itemized listing.
By Jana Garman, Consultant, and Amanda Shapiro, Senior Consultant at DCI Consulting Group