Legal Alert: OFCCP Outlines New Audit Procedures

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Recently, the Office of Federal Contract Compliance Programs (OFCCP) issued new procedures for conducting supply and service compliance reviews. While the directive is dated December 16, 2010, it was not released by the OFCCP until February 2011. The new procedures are in effect for supply and service evaluations scheduled on or after January 1, 2011.

Since July 25, 2003, the OFCCP compliance evaluations have been processed under the Active Case Management (ACM) procedure. With a directive issued December 2, 2010, the OFCCP rescinded the ACM process because "it did not allow OFCCP to effectively use all of its investigative tools." The contracting community has been awaiting the issuance of new procedures for conducting supply and service audits. The new procedures are entitled Active Case Enforcement (ACE) procedures.

Please see full alert below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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