If the off-site analysis of the data that the CO obtained during the desk audit and on-site review result in no violations being found, the CO should close the FAAP compliance evaluation. However, if there are findings of discrimination or other violations, the CO should proceed in accordance with Chapter 8 and the issuance of a PDN or NOV, as warranted.299
The CO must follow FCCM Chapter 8 in each FAAP compliance evaluation that results in a finding of a violation. If the CO issues a CA to correct identified violations, then the CA, closing documents and letters must clearly reflect that the CO conducted a compliance evaluation of a FAAP and Itemized Listing data, and indicate the limited scope of the evaluation.300 As previously noted, the contractor may also have an establishment-based AAP(s) covering the remainder of its workforce and employment actions that OFCCP did not review as a part of the FAAP review.
299. See FCCM Chapter 8: Resolution of Noncompliance.
300. See FCCM Chapter 7 – Employment Discrimination Remedies, and FCCM Chapter 8 – Resolution of Noncompliance.