4B10 Review of Past OFCCP Compliance Actions

Based upon the information gathered in FCCM 4B, Pre-Desk Audit Actions, the CO should review the contractor’s compliance history to identify cases with violations involving a corporate-wide policy or practice. Examples would be violations for prior discriminatory acts, failure to conduct a self-audit, discriminatory benefits or testing practices, or unlawful medical screening practices. As appropriate, a CO can contact the OFCCP office that conducted the evaluation or investigation to obtain further information on the violations, their resolution and whether they applied to management jobs. The purpose of obtaining this information is not to revisit closed compliance actions, but to determine whether the same problem could exist corporate-wide. If the information indicates a potentially corporate-wide problem, especially one that could affect management jobs, the CO should include a review of that area in the On-site Plan.