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Guidance During OFCCP Audits

A Quarles & Brady client unwittingly became a federal contractor and was audited by the Office of Federal Contract Compliance Programs (OFCCP). The client had not complied with the OFCCP’s record-keeping and job posting obligations or engaged in any outreach to women, minorities, covered veterans, or individuals with disabilities. The OFCCP gathered the needed information from the client and then issued a Notice of Violation and draft conciliation agreement. The proposed conciliation agreement outlined 10 pages of obligations and required reporting to the OFCCP for two years. The client then sought advice from us regarding the audit. We objected to the OFCCP’s proposed conciliation agreement and talked to the agency about our objections to the agreement and the OFCCP’s approach. Based on our advice, the client declined to sign any conciliation agreement with the OFCCP. Less than two weeks later in 2011, the OFCCP administratively closed the audit without a conciliation agreement or reporting obligations to the OFCCP.