OFCCP Compliance Tip: Documenting OFCCP Data Requests
In 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!)