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Real Results:

Major Discrimination Charges Threatened

$20 Billion Healthcare Enterprise

Turnaround of Contentious Audit Situation



Arbor was called in after the OFCCP Desk Audit materials were submitted. Based on additional Agency requests, it appeared the audit was going to result in: major violations; charges of discrimination in the selection process; disability discrimination; and steering claims.

The data was several years old, at this point, and the Agency was entrenched in its position that the organization was acting improperly.


The Arbor Team started the project by accurately reconstructing the data, especially the voluminous applicant flow data, which include: evergreen positions; parent-child requisitions; inconclusive disposition codes; and data from two different applicant tracking systems.

During this time, the OFCCP sent numerous additional data requests; conducted several visits on-site; and interviewed scores of employees and managers.

Arbor supported the client at every step, readying personnel for interviews, and preparing multiple, complex data responses, ensuring consistency and accuracy.


After nearly two years of Arbor refuting the OFCCP’s claims point by point, submission by submission, the audit was closed with only minor technical violations, with none of the initially threatened discriminatory or potential charges. Perhaps equally important, no negative publicity or litigation has resulted for this major employer.

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