A desk audit typically enables COs to review a contractor’s compliance with its affirmative action and equal opportunity obligations at a particular establishment. COs must conduct desk audits following these general principles:
a. Equal Employment Opportunity (EEO). A contractor’s personnel policies and practices must not have the purpose or effect of discriminating because of race, color, religion, sex, sexual orientation, gender identity, national origin, disability or status as a protected veteran, or because they discussed, inquired about, or disclosed their pay or, in certain circumstances, the pay of other employees. Contractors must eliminate and remedy discrimination that, for example, limits a job applicant’s or an employee’s ability to engage in open and fair competition for a job or position, or that results in paying employees differently based on race, sex or membership in other protected classes.
b. Affirmative Action Program. An AAP is a management tool. The written AAP includes diagnostic and self-monitoring components as well as a set of specific and result-oriented policies and procedures designed to achieve EEO.
c. Inclusion and Acceptability. An AAP is assessed for “inclusion” and “acceptability.” This chapter discusses these concepts more fully in sections 1E – 1H of this chapter.
When conducting the desk audit, COs focus on a review of the following areas:
a. Workforce Structure, Personnel Policies and Procedures. COs examine a contractor’s personnel policies and procedures to determine if they warrant in-depth investigation, such as an on-site review. Likewise, an examination of a contractor’s basic organizational or workforce structure may reveal irregularities that merit investigating.
b. Problem Areas and Action-Oriented Programs. COs examine whether a contractor identified any problem areas, and, if so, whether the contractor developed and executed action-oriented programs designed to correct the problem areas. In doing so, COs should seek to determine at least these specific things:
- Whether there are any areas with a lack of progress toward established goals;
- Whether further information is needed in any area; and
- Whether an on-site visit is needed to evaluate the contractor’s efforts to develop and implement AAPs designed to improve opportunities for minorities, women, people with disabilities and protected veterans.
c. Potential Discrimination. COs must be aware of the signs of potential discrimination. Being aware of and alert to these signs allows a CO to assess when further investigation is required. Below are examples of signs of potential discrimination.
- Individuals in a particular race, sex, or ethnicity are significantly overrepresented or underrepresented in a particular area of the workforce.
- Indications exist that an employment practice or procedure has adversely affected individuals based on their race, sex, or ethnicity.
- Compensation practices of a contractor result in differences in pay that appear to be based on race, sex, or ethnicity.
- Indications exist that leave for family caregiving is applied differently for men and women.
- The contractor has policies that could adversely affect employees with disabilities, such as a “no leave” policy or a policy requiring 100% recovery before allowing an employee to return to work.