OFCCP recently mailed out close to 2,500 Courtesy Scheduling Announcement Letters to employers providing advance notice of upcoming audits. Up against the fast-approaching end of the Agency’s fiscal year, OFCCP began initiating actual audits immediately after the CSALs were mailed.

While we can certainly expect OFCCP to continue to focus their enforcement efforts on traditional areas of concern (e.g., compensation and new hires adverse impact), employers must craft their defenses to respond to OFCCP’s latest enforcement plays, including in-depth interviews of compensation professionals, robust statistical analyses of pay practices, novel investigations into steering issues, and close scrutiny of compliance with the new veterans and disability regulations. OFCCP’s offense has changed and so must your defense.