At the conclusion of a desk audit, COs should contact the contractor to schedule the on-site review and discuss any additional material they need for further analysis. The COs should include any unresolved issues identified during the desk audit in the SCER.
The CO will prepare a letter to the contractor reiterating that the evaluation is a CMCE, confirming the on-site date and listing any additional data needed. The notice will state that the on-site review will begin with an entrance conference to discuss those issues with the CEO or appropriately designated corporate officials.
The notification letter to the contractor should identify the additional information needed. When the needed information is regarding the jobs filled at or above the level where nonfavored group participation drops, the data requested should be sufficient to identify the specific jobs filled and how they were filled (e.g., by hire, by promotion, by transfer). COs should note in the data request that if the contractor filled such jobs by promotion or transfer from subordinate establishments within the corporation, the contractor should identify the originating establishment. As pertinent, COs should request any other needed activity data (such as applicant flow and terminations) and general information (e.g., jobs in subordinate establishments included in the corporate AAP).
The notification letter must also provide a high-level summary of any preliminary indicators of discrimination identified during the desk audit. COs should note in the letter, however, that the list is not exhaustive, nor does it limit the scope of OFCCP’s authority to confirm compliance with other requirements or investigate other potential violations that it discovers during the course of the compliance review.