Surviving an OFCCP Compliance Audit--Best Practices to Limit Liability and Costs

Employers have the responsibility of understanding federal regulations, contract standards, and compliance guidelines as part of compensation programs that receive federal funding. Some of the key practices that employers should know would include:

       -How are compliance evaluations and complaint investigations conducted?

-What types of information is analyzed in periodic compliance reports?

       -How are conciliation agreements designed that apply to contractors and subcontractors who are in violation of regulatory requirements?

       -What types of sanctions and enforcement actions might be recommended to the Solicitor of Labor?

       -What steps might employers take to achieve a higher level of compliance with these standards? 

Christine Hendrickson, Senior Counsel

Seyfarth-Shaw, LLP

Labor and Employment OFCCP Compliance, Affirmative Action & Diversity Team

Christine Hendrickson is senior counsel in the Chicago office of Seyfarth Shaw LLP, where she is a member of the firm’s Labor and Employment OFCCP Compliance, Affirmative Action & Diversity Team.

Ms. Hendrickson assists clients of all sizes and industries in matters involving OFCCP proceedings, including audits, enforcement actions, and other litigation. Ms. Hendrickson also works with clients to revamp their personnel practices; build “best practices;” and ensure compliance with mandates impacting recruitment, hiring, promotion, compensation, performance evaluation, discipline, and termination. In addition, Ms. Hendrickson provides strategic advice and counseling to employers on diversity programs, reductions-in-force, pay equity and employment compliance diagnostics. She also represents employers in a range of litigation matters challenging pay, promotion, hiring, and other personnel decisions.

Examples of Ms. Hendrickson’s work include: preparing a multi­year pay equity diagnostic for a Fortune 200 company, conducting a comprehensive employment diagnostic that culminated in a report to the CEO and the Board of Directors of a Fortune 200 company, devising alternative diversity metrics and working on a strategy to tie diversity metrics to incentive compensation, and advising major international corporate clients regarding reductions-in-force. Ms. Hendrickson has a Bachelor’s degree from Colby College and a Juris Doctor degree from the University of Michigan Law School and she graduated cum laude from both institutions.

Sample Publications

Co-Author, "Federal Contractor News Roundup: Paid Sick Leave, Pay Secrecy, Posters, Plus More," Management Alert, Seyfarth Shaw LLP (September 8, 2015)

Co-Author, "OFCCP Proposes Anti-Pay Secrecy Regulations for Federal Contractors," One Minute Memo, Seyfarth Shaw LLP (September 18, 2014)

Co-Author, "OFCCP Proposes New Equal Pay Report," Management Alert, Seyfarth Shaw LLP (August 8, 2014)

Co-Author, "OFCCP Issues Additional FAQs: Clarifies Data Collection Analysis, Self-Identification, Utilization Goals and Hiring Benchmarks," Management Alert, Seyfarth Shaw LLP (June 23, 2014)

Co-Author, "OFCCP Posts New FAQs Clarifying Implementation of Section 503 and VEVRAA Regulations," Management Alert, Seyfarth Shaw LLP (February 19, 2014)

Co-Author, "OFCCP Finalizes Disability Self-Identification Form; Seyfarth Offering Fixed Fee Compliance Packages," One Minute Memo, Seyfarth Shaw LLP (January 27, 2014)

Co­Author, “OFCCP Wins Major Battle Over Coverage Of Some Health Care Providers,” Management Alert, Seyfarth Shaw LLP (April 5, 2013)

Co­Author, “OFCCP’s New Compensation Plan Provides Little Direction,” One Minute Memo, Seyfarth Shaw LLP (February 27, 2013)

 Co­Author, “What The Presidential Election Means For Federal Contractors: Insight Into What’s Ahead For Affirmative Action,” One Minute Memo, Seyfarth Shaw LLP (November 9, 2012)

Co­author, “Statisticians Caution EEOC on the Challenges of Collecting and Measuring Pay Equity Data, “ Management Alert, Seyfarth Shaw LLP (September 12, 2012)

Co­author, “Federal Contractors and Subcontractors be on the Alert: Federal Government Takes a Step Towards Creating the Elusive List of Federal Subcontractors,” Management Alert, Seyfarth Shaw LLP (August 24, 2012)

***PARTNER EVENT: TPSU***

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