By Amanda Bowman
As noted in a prior blog, the Office of Federal Contract Compliance Programs (OFCCP) began issuing administrative closure letters for open audits following Secretary Lori Chavez-DeRemer’s release of Order 08-2025 on July 2, 2025. While the rollout has been modest, the agency has continued issuing letters since July 10, 2025.
It is not clear what methodology OFCCP is using to issue these closures, as it does not appear to be by scheduled date or submission date. Although closures initially seemed limited to audits scheduled out of the Southwest and Rocky Mountain Region (SWARM), DCI clients with audits in the Midwest, Southeast, Pacific, and Northeast have received closure letters. However, it appears that no region has closed all of their open audits, which suggests that OFCCP is not working region-by-region either.
While DCI anticipates that all open audits will eventually receive a closure letter, the slow pace and geography of the closed audits and the offices that have issued the closure letters raises questions. So far, roughly 40% of DCI-supported audits have received their closure letters. Most of the closure letters are being issued by OFCCP’s San Antonio District Office, although Midwest closures have been issued by the Dallas District Office.
Compliance Reviews with Conciliation Agreements Closed
Notably, DCI is aware of closures for some audits with conciliation agreements that involved ongoing reporting obligations. These audits were closed using the same standard letter as open audits with no mention of the conciliation agreements or reporting obligations. One of these agreements only had violations related to Section 503 of the Rehabilitation Act (Section 503) and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA), whereas another example had about 80% of the violations noted in the conciliation agreement related to Section 503 and VEVRAA. With the regulations regarding individuals with disabilities and veterans largely remaining, why would active and open-conciliation agreement reporting obligations not continue? It is possible OFCCP’s limited remaining workforce and potential shuttering after the fiscal year may be the explanation.
It remains unclear why some audits are closed quickly while others within the same Corporate Scheduling Announcement List (CSAL) or region remain open. We do not yet know if OFCCP is applying specific criteria, acting randomly, or simply working through audits in an unpredictable order.
DCI will continue to monitor these developments and will provide updates as more information becomes available.
