All potential discrimination problems that a CO identifies during the desk audit must be summarized, as appropriate, in Part A (Preparation), Part B.VII (Employment Activity Data Analyses), and Part B.VIII (Other Problems Identified for On-site Investigation) of the SCER. These summaries must include any problems the CO identifies while reviewing compliance history, the contractor’s AAPs, and any problems the CO identifies during the review and analyses of Itemized Listing data.
For each potential discrimination problem a CO identifies, an on-site investigative plan must be developed. If the CO finds indicators of what appears to be a single potential discrimination problem through more than one analysis, such as an area of minority concentration with statistical indicators of discrimination for minority promotions out of the area, the CO only needs to describe the problem once in the On-Site Plan. The On-Site Plan should be as specific as possible and will set priorities for the documents to be gathered.75
75. FCCM 2C03 – On-Site Plan.