Developing Meaningful Action-Oriented Programs and Documenting Them - Virtual Event

  • April 21, 2023
  • 9:00 AM - 10:30 AM
  • Virtual Event

Registration is closed

Developing Meaningful Action-Oriented Programs and Documenting Them

The OFCCP is proposing to amend its audit scheduling letter, and even though we don’t yet know what the final audit scheduling letter will look like, the overriding theme of the letter is OFCCP’s desire to have more documentation and evidence to verify that employers in fact are using the AAP as a meaningful management tool.  Long gone are the days when employers could swap out last year’s dates on the AAP cover page and assign responsibility to a new person, but leave all other boilerplate unchanged.  Whether your AAP identifies placement goals for minorities and women, adverse impact in hiring or promotions, pay disparities, hiring percentages below the Veteran Hiring Benchmark, or disability employment percentages below the OFCCP’s 7% utilization goal, your organization is expected to develop action-oriented programs.  Moreover, what you develop now in 2023 could have ramifications as far into the future as 2025 because OFCCP has the legal authority to look back two years in any audit.   


Alissa Horvitz is a Member Attorney in the Northern Virginia law firm she co-founded with her friend and partner Josh Roffman. Roffman Horvitz focuses its practice in the legal space where employment law and data analytics intersect. In addition to preparing affirmative action plans, helping employers that are being audited by OFCCP, and conducting privileged pay equity analyses and adverse impact analyses, Roffman Horvitz conducts analyses of applicant tracking systems and performs mock internal audits, also under attorney client privilege. Alissa is a member of the Washington Metro ILG and the Baltimore ILG. She enjoys presenting at local, regional, and national ILG conferences.

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