OFCCP Compliance Tip: Documenting OFCCP Data Requests

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OFCCP Compliance Tip: Documenting OFCCP Data Requests

John C. FoxIn addition to our Week In Review (WIR) and OFCCP Compliance Alerts, we added a new subcategory called Compliance Tips. These posts are quick snippets of advice for federal contractors, provided by a variety of field experts. This week’s tip is from John C. Fox, President and Senior Partner at Fox, Wang & Morgan P.C. where he represents companies and tries cases in state and federal courts throughout the United States.

Today’s OFCCP Compliance Tip: Documenting OFCCP Data Requests
During OFCCP audits, your habit should be to always demand (politely) of OFCCP Compliance Officers that they reduce their many requests for documents and information to writing (typically, these days, via e-mail). This insures that the OFCCP CO has been thoughtful and more precise in his/her request and you are precisely clear what OFCCP wants before you start a perhaps otherwise futile gopher chase. Also, you now have a record of the request which becomes important as the audit drags on into years and newly assigned COs pick up the file sometimes oblivious to history. (Those who do not read history are doomed to repeat it!)

Looking to learn more about the regulations and network with other OFCCP compliance professionals? Attend the DirectEmployers 2015 Annual Meeting & Conference in addition to the Affirmative Action Briefing pre-conference event taking place May 13-15, 2015 in Indianapolis! Learn more and register at DEAM15.DirectEmployers.org.
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About the Author

John C. FoxJohn C. Fox, Esq. is President and Senior Partner at Fox, Wang & Morgan P.C. where he represents companies and tries cases in state and federal courts throughout the United States. Mr. Fox has extensive trial experience, having spent more than 300 days in trial. Mr. Fox was also lead trial counsel in the first of the four wage-hour class actions known to have been tried in California and was lead trial counsel in what are believed to have been the two largest disability law suits in the United States. He is an across-the-board employment lawyer representing management nationwide.View all posts by John C. Fox »