When appropriate, the CO should promote early and efficient corporate-wide compliance by examining whether it is possible to resolve indicators of discrimination and other material violations uncovered at the desk audit before proceeding to an on-site investigation.79 If early resolution is not possible, the CO must proceed with an on-site review if:
- The contractor provided insufficient data to conclude the review at the desk audit stage;
- There are indicators of potential discrimination, failure to provide a completed AAP, complaints or problems that merit an on-site review; or
- The contractor has been identified for a complete compliance review following OFCCP selection procedures.
In instances where problems are resolved through a document submission during the desk audit, the CO’s on-site review may consist of technical assistance to ensure that the contractor is aware of its obligations.80
79. See Directive 2019-02, “Early Resolution Procedures.”
80. FCCM 2L – Equal Opportunity Clause and Other Requirements.