A CMCE is always a full review. COs use the SCER, with the addition of the CMCE-specific Part D which addresses those elements unique to a CMCE.264 The evaluation of a corporate headquarters includes a review of the written AAPs to ensure that they include all jobs for which the headquarters has decision-making authority, regardless of where those jobs are physically located. For example, jobs for which the corporate headquarters retains decision making or approval and disapproval authority usually include senior managers of the various corporation establishments. Such jobs are often important contributors to feeder pools for middle and senior-level corporate management positions.
Corporate wide policies will also be examined as part of the CMCE, including those pertaining to protected veterans with disabilities, individuals with disabilities, and the sharing of compensation information. A CMCE can be expanded beyond the corporate headquarters if, during the course of the CMCE, the CO becomes aware that problems exist at establishments outside the corporate headquarters.265 In this instance, the CO should discuss with his or her supervisor266 whether it would be appropriate to expand the compliance evaluation beyond the headquarters. If they decide to expand the evaluation, the CO should contact the contractor, explain the reasons for and scope of the expansion, and request appropriate records and other evidence regarding the additional issues(s) to be investigated.
For example, the CMCE may need to include an analysis of feeder pools at subordinate establishments. In determining whether to include such an analysis, the CO should consider the degree to which the contractor has historically and recently filled corporate headquarters management positions from elsewhere in the corporation, and the degree to which corporate headquarters tracks and monitors the progress of key personnel in subordinate establishments. COs should refer to FCCM 4H04, Cross-Establishment Movement, for additional information on feeder pools and related issues.
Likewise, the highest-level management positions held by members of nonfavored groups may be outside the corporate headquarters. Therefore, when doing a CMCE, the CO must request data from the contractor related to other establishments, when necessary, to determine the existence and extent of a “glass ceiling” within the corporation.
264. FCCM 4B – Pre-Desk Audit Actions.
265. 41 CFR 60-2.30(b).
266. The regional and national offices are consulted when determining whether to expand the scope of a CMCE.