Ad-Hoc OFCCP Compliance Review Support

DCI is available to support Client during any compliance review by OFCCP. The nature of the work to be done for Client during the compliance review will be at Client‘s discretion.

Services Included as Part of Fixed Fee Cost for Plan Preparation

DCI will provide the following as part of the fixed fee cost for the preparation of Client‘s plans:

• DCI will ensure that Client receives the Plans and other materials described in the statement of work.
• DCI will prepare a submission letter that can be used by the client to transmit to OFCCP the plans and other items required by OFCCP at the start of a compliance review. DCI will also provide additional resources and templates for the client’s use.
• DCI will hold a one-hour risk management call to discuss the pending compliance review and major issues that may surface during the compliance review.

Additional Services That DCI Can Provide During a Compliance Review

DCI can provide additional services to assist Client with the submission of items requested by OFCCP. These services will be billed on an hourly basis unless already part of Client‘s existing contract.

• DCI can prepare statistical supplements for required reports if Client is more than six months into its current affirmative action plan year, if DCI is not currently providing these reports as detailed in another section of this statement of work.
• DCI can assist Client in compiling, preparing, and reviewing materials requested at the start of a compliance review that are not a part of the services provided as part of the fixed-fee portion of the affirmative action preparation fixed fee done by DCI. (For example, DCI can provide six-month updates)..)
  • If needed, DCI can also help to prepare documentation regarding outreach and recruitment activities, additional statistical reports, or other documentation that Client has prepared to meet OFCCP’s requests.
• DCI can provide support for compliance reviews after the initial submission to OFCCP, including development of written responses, quality review of documents, and strategy calls.

Additional Services That DCI Can Provide Regarding Use of Artificial Intelligence

In their audit scheduling letter and itemized listing, OFCCP requests “information and documentation of policies, practices, or systems used to recruit, screen, and hire, including the use of artificial intelligence, algorithms, automated systems or other technology-based selection procedures.”. DCI offers a variety of services related to this item, including:

• Partnering with clients to develop a matrix of policies, practices, or systems used to “recruit, screen, and hire”. This inventory typically includes a description of the process, its use, history, volume, implementation characteristics and available documentation.
• Performing an expert evaluation of the extent to which those policies, practices or systems “use of artificial intelligence, algorithms, automated systems or other technology-based selection procedures”. This analysis typically focuses on the underlying methodology used to produce scores, classifications or other data points that are then used in employment decision-making or adjacent decisions.
• Conducting an expert risk assessment that uses the Uniform Guidelines on Employee Selection Procedures as a starting point, which focuses on evidence related to (1) adverse impact, (2) job-relatedness, and (3) reasonable alternatives. Depending on the details of the process, other factors related to explainability, transparency, fairness, and accommodation may also be of interest.
• Directly analyzing the adverse impact of decisions stemming from policies, practices, or systems of interest.

This work will be performed on an hourly basis, and DCI will work with clients to define the scope of this work before any work is performed.