Civil Rights

Contractor Compliance Program: External EEO

Compliance Reviews

The Arizona Department of Transportation Civil Rights Office conducts annual compliance reviews to ensure contractors and subcontractors performing on federal or federal-aid contracts are in compliance with Equal Employment Opportunity (EEO) requirements. Mandated by the Federal Highway Administration (FHWA), annual compliance reviews are conducted on projects throughout the state during every construction season.

The review process consists of the following components: Planning, Contractor Notification Preliminary Analysis, On-site verification and Interviews, Exit Conference, Compliance Determination and where necessary, Corrective Action.

These frequently asked questions (FAQs) provide some essential background information to contractors or subcontractors undergoing an annual compliance review.

What is a compliance review?

A compliance review is the process for determining whether a contractor working on a project with federal funds is meeting EEO program requirements.

What authority does ADOT Civil Rights Office use to identify deficiencies?

ADOT's authority to identify deficiencies derives from 23 C.F.R.§230 and the Required Contract Provisions for Federal-Aid Construction Contracts (Form FHWA-1273).

How long does an on-site visit typically take?

The entire on-site visit typically takes between two to three hours.

What happens during the preliminary analysis?

A review of the contractor’s policies, practices, and procedures related to EEO compliance and workforce information. Depending upon the results of the initial analysis, additional information may be requested.

Does an annual compliance review concern a project, business or both?

Both. An annual compliance review is designed to ensure that the contractor is meeting EEO program requirements as they relate to both the project and their core business structure.

Does a contractor have any say in who is interviewed?

No. The Contract Compliance Specialist and/or FHWA representative have sole discretion when it comes to project site interviews.

Who is the primary point of contact during a compliance review?

The contractor should contact the Contractor Compliance Manager listed in the Notification of Compliance Review letter.

What is a Voluntary Corrective Action Plan (VCA)?

The VCAP is a document that outlines both the deficiencies uncovered during the annual compliance review and the time frames for implementing corrective measures.

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If you have questions or comments about ADOT's External EEO Contractor Compliance Program Contact Us.

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