The second major stage in a compliance review of a construction contractor is the on-site review. The purpose of the on-site review is to determine if the contractor complied with the requirements of Executive Order 11246 and, as applicable, Section 503 and VEVRAA. During this review, COs will examine personnel activity, compensation data and work hours. In addition, they will evaluate the contractor’s affirmative action efforts to comply with the Executive Order, Section 503 and VEVRAA, if applicable. There are several activities that take place during the on-site review process and they include:
- Entrance conference (FCCM 3G);
- Review of records such as personnel activity, compensation and work hours (FCCM 3H);
- Evaluation of policies, practices and procedures assessing compliance with the Executive Order 11246 affirmative action specifications (FCCM 3I);
- Evaluation of compliance with Section 503 and VEVRAA obligations (FCCM 3N);201
- Employee and supervisor interviews (FCCM 3J);
- Physical inspection of the contractor’s worksites (FCCM 3K);
- Identification and investigation of discrimination (FCCM 3O); and
- Exit conference (FCCM 3P).
Each of the activities of the on-site review process are discussed in FCCM 3G through 3P.
201. Compliance with Section 503 and VEVRAA obligations does not occur if the contractor is working only on federally assisted construction contracts.