5C Desk Audit
Initially, the CO will determine whether the FAAP submission is for the functional or business unit identified in the Scheduling Letter. Additionally, the CO must refer to the FAAP agreement for a description of the functional or business unit and verify contact information for the corporate contact person.
If the CO conducting the FAAP compliance evaluation finds problems, he or she should contact the corporate contact person for clarification or additional information before proceeding with the desk audit. If the CO identifies significant changes to the functional or business unit, such that the functional or business unit scheduled for review no longer exists or has substantially decreased or increased in size, the CO should notify his or her supervisor and contact the FAAP Branch Chief to discuss the issue.
The CO will conduct the desk audit as described in FCCM 1C through FCCM 1R with the exception that the CO will analyze the data by functional or business units. In some instances, during a FAAP compliance evaluation, the CO will not have sufficient data to perform an EEO-1 trend analysis in accordance with FCCM 1K. However, they should conduct all other analyses required in a desk audit. Even though the CO may not have sufficient data to conduct the EEO-1 trend analysis, they may be able to use the JAAR analysis as described in FCCM 1N01. This analysis can prove meaningful in analyzing how employees are placed and may show when limited opportunities exist for specific groups throughout the functional or business unit. This analysis can be conducted by job group despite the possibility of job groups being spread across many different locations. The CO should complete all applicable sections of the SCER and further investigate identified problem areas and indicators of adverse impact during the on-site review.
In conducting analyses of employment decisions like hiring, terminations, promotions and compensation, the CO should examine the data by function and business unit, and job group and job title, or any combination thereof. If indicators of discrimination are identified during the desk audit, the CO, in conjunction with their manager, must consult with the Branch Chief of Expert Services to identify the best methods for analyzing the data.
Contractors with approved FAAP agreements must continue to comply with Section 503 and VEVRAA obligations by: (a) creating and maintaining Section 503 and VEVRAA FAAPs for the same functional or business units that are covered by their Executive Order 11246 FAAPs; or (b) creating and maintaining establishment-based Section 503 and VEVRAA AAPs for each of their establishments. Contractors must inform OFCCP which method they will use to comply with its Section 503 and VEVRAA affirmative action obligations during the FAAP negotiation or certification process. The method chosen by the contractor will be recorded in the FAAP Agreement. Under either arrangement, contractors must make their VEVRAA or Section 503 establishment-based AAPs or FAAPs available for review by employees at each of their establishments.
When contractors with approved FAAP agreements are scheduled for compliance evaluations, they must also submit their Section 503 and VEVRAA FAAPs for the functional or business unit under review. If a contractor uses establishment-based AAPs to comply with Section 503 and VEVRAA, it must submit to OFCCP its AAPs for all establishments within the functional or business unit under review. The CO will review all Section 503 and VEVRAA establishment-based AAPs as described in FCCM Chapters 1 and 2.
During the review, the CO must ensure that all employees covered by the functional or business unit are included in the Section 503 and VEVRAA AAP submissions. A contractor using a FAAP for Section 503 and VEVRAA should apply the Section 503 utilization goal on a job group basis, using the job groups in their Executive Order 11246 FAAP. The contractor may apply the VEVRAA hiring benchmark, at its discretion, to each of its job groups or to the functional unit as a whole. A contractor using establishment-based AAPs for Section 503 and VEVRAA, even though it has an Executive Order 11246 FAAP, should apply the Section 503 utilization goal to job groups created in accordance with 41 CFR 60-2.12 or, if it has a total workforce of 100 or fewer employees, by applying the goal to its workforce as a whole, if it chooses to do so. The contractor may apply the VEVRAA hiring benchmark, at its discretion, to each of its job groups or to the establishment as a whole.