Once the CO identifies the analytical framework needed to investigate the complainant’s allegations, the CO must develop the Investigative Plan. The Investigative Plan will serve as a checklist or “road map” for the investigation. While the Investigative Plan may not identify every step along the way, it should contain the major actions to take. The Investigative Plan should incorporate the investigative framework for each allegation, list the data to obtain and identify the interviews to conduct (and specific questions to ask). The Investigative Plan should reflect the logistics for the on-site investigation, such as the OFCCP staff members who will participate in the on-site review and the dates for the on-site review.
The Investigative Plan should include a complete list of the allegations in the complaint and a summary list of all interviewees, interview questions, and data and information needs. Specific to each allegation, the elements the CO should include in the Investigative Plan are below.
- Statement of the allegations and the nature of the allegations (e.g., systemic, individual disparate treatment in promotional opportunity, denial of reasonable accommodation, harassment);
- Interview of the complainant regarding the specifics of the allegations;
- Interviews of management officials (listed by name or position) and the issues to address;
- Interviews of nonmanagement individuals (listed by name or position) and the issues to address;
- Interviews of witnesses the complainant has identified and the issues to address;
- Specific records and materials to review and analyze;
- Analyses to conduct;
- On-site investigation (agreed upon date); and
- Contact with third parties, when appropriate.