The Office of Federal Contract Compliance Programs has released information to clarify the methodology used for selecting supply and service contractors for compliance evaluations. The report details the various steps taken by OFCCP to identify all possible current federal contractors, then took the following steps to develop the list of contractors for possible compliance evaluations:
Removed establishments:
- currently under review by the agency
- that completed a compliance review within the past five years
- currently covered by a conciliation agreement or consent degree
- that had a separate facility exemption
- that had contracts expiring before March 31, 2018
- that were still available for scheduling from a prior list
- that had less than 70 employees
- that were independent subsidiaries of corporations that were not covered contractors
Then:
- created separate pools for each district office based on the establishments’ addresses
- Capped the list at 1,000 establishments
- Sorted each district office list by number of employees (highest to lowest)
The OFCCP report says the agency has also ensured that an organization would not receive more than 10 compliance evaluations total and that a district office would not have more than four establishments in the same organization. Once the list was finalized, the establishments “were randomly ordered” and uploaded into the agency’s Case Management System.
The OFCCP noted that this new list was added to the prior scheduling list because the agency “does not purge unscheduled cases from prior lists before releasing a new scheduling list.”
Meaning, that if a contractor was on the prior list, it will still receive a scheduling letter notwithstanding the creation of this new scheduling list. This methodology applies only to the most recent round of compliance evaluations – not past or future lists.
