An On-Site Plan is an important step and COs must develop one before each on-site review. Although the scope of the on-site review may change as a result of the on-site observations and evidence, the On-Site Plan serves as the initial outline or “road map” for conducting the on-site review. In some cases, it may be helpful to involve staff from the regional solicitor and DPO in devising the On-Site Plan. For contractors with complex compensation systems (such as education, information technology, finance, or healthcare sectors), attorneys and DPO statistical experts may help ensure that appropriate information, documents and data are obtained.90
The On-Site Plan must include each problem area identified during a desk audit and described on the SCER in Part B. For each problem area, the On-Site Plan must identify or describe the data and records the CO will obtain and review, interviews that the CO will conduct, and any other known relevant materials the CO will review while on-site. For example, additional information may include materials related to the desk audit findings such as personnel records, payroll records, applications and resumes, and materials not included in the original submission such as employment advertisements and position descriptions. In addition to individuals who are interviewed as a routine matter (for example, the human resources manager), interviewees should include individuals relevant to the investigation of any indicators of discrimination identified at the desk audit stage (for example, selection officials, employees and applicants).
The On-Site Plan must also include a list of technical items, such as the posting of the Equal Employment Opportunity Is the Law poster (“EEO is the Law” poster) and the required supplement, that the CO will verify while on-site. Additionally, the plan must identify field office staff who will participate in the on-site review, and their roles and responsibilities. The On-Site Plan must also include the projected dates for the on-site review, as discussed with the contractor.
If a CO is going on-site as part of a focused review, the On-Site Plan will reflect the more limited scope of this type of review. Similarly, if a CO is going on-site to conduct a compliance check, the On-Site Plan will be narrower because the plan will not encompass all of the elements of an On-Site Plan that the CO would develop for a comprehensive compliance review. When going on-site for a compliance check, COs must use the Compliance Check Control Sheet to record whether the contractor maintained the appropriate records or whether the contractor needs to provide additional information and documentation.91
90. See Appendix A-4 for a sample On-Site Plan.
91. See Figure F-1 – Compliance Check Control Sheet.