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Compliance Checks Frequently Asked Questions

A compliance check is a determination of whether the contractor has maintained records consistent with Executive Order 11246, Section 503 of the Rehabilitation Act (Section 503), and the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA). The check includes a review of the affirmative action program (AAP) results under each of these laws, in addition to job advertisements and examples of reasonable accommodations for persons with disabilities.

  1. What is a Compliance Check?
  2. Does a compliance check include a mandatory onsite?
  3. What AAP results will OFCCP review under Executive Order 11246?
  4. What AAP results will OFCCP review under Section 503 and VEVRAA?

 


 

1. What is a Compliance Check?

A compliance check is a type of compliance evaluation in which OFCCP seeks to determine whether the contractor has maintained certain records: prior year AAP results, job advertisements (including state employment service listings), and examples of accommodations for individuals with disabilities. During a compliance check, OFCCP will also check the General Services Administration System for Award Management database to determine if a contractor has self‐certified that it has AAPs.

 


 

2. Does a Compliance Check include a mandatory onsite?

No, the contractor has the option to provide the documents either on site or off site.

 


 

3. What AAP results will OFCCP Review under Executive Order 11246?

For Executive Order 11246, OFCCP will review the contractor’s report on goals for women and minorities, as well as the good faith efforts it undertook to remove barriers and expand employment opportunities for those groups. For more information, refer to the Executive Order 11246 regulations at 41 CFR ยง60‐1.12(b).

 


 

4. What AAP results will OFCCP Review under Section 503 and VEVRAA?

Under the Section 503 and VEVRAA regulations, contractors must assess the effectiveness of their external outreach and recruitment efforts. See 41 CFR 60‐300.44(f)(3), 60‐741.44(f)(3). OFCCP will review the documentation of these assessments during a compliance check. An overview of the requirements for VEVRAA can be found here, and Section 503 requirements can be found here.