“My wife is always trying to get rid of me. The other day she told me to put the garbage out. I said to her I already did. She told me to go and keep an eye on it.”
Rodney Dangerfield
Such is the problem with affirmative action plans – adverse impact reports evaluating applicants vs. hires are only as good as the underlying data that goes into them (i.e., garbage in, garbage out). As a result, federal contractors should “keep an eye on it” and devote the necessary time and resources to consistently monitor and clean-up their applicant flow log (AFL) databases. If they don’t, the result is a ticking data time bomb that can explode in a contractor’s face (or wallet) during an audit by the Office of Federal Contract Compliance Programs (OFCCP).
However, it doesn’t have to be this way. Contractors can instead take basic preventative steps to look for and correct the following Top 5 AFL mistakes before an audit occurs:
In the end, a contractor’s AFL should ultimately match one thing – reality. However, what does or does not get counted in a given plan year from a regulatory standpoint can get confusing, especially when overlaid with the OFCCP’s Internet Applicant rules that went into effect in 2006. Federal contractors should, therefore, consult with their counsel when developing “applicant” tracking procedures to ensure that the AFL which supports an affirmative action plan is as accurate as possible.