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The Oklahoma Department of Transportation (ODOT) is required to ensure that all contractors, subcontractors, vendors and material suppliers do not discriminate in employment and contracting. The Federal Highway Administration (FHWA) has specific Required Contract Provisions (FHWA-1273) which are applicable to all contractors and subcontractors who hold Federal or Federal-aid contracts of $10,000 or more.

ODOT administers its Contractor Compliance Program in accordance with Title 23, Code of Federal Regulations, Highways, Part 230 and the ODOT Contract Compliance Program.

For additional information regarding program requirements, please click here


What is a Contract Compliance Review?

Contractor Compliance Reviews are performed on ODOT projects in order to monitor the utilization of minorities and females on Oklahoma Department of Transportation (ODOT) projects. These are comprehensive reviews conducted to determine a contractor’s compliance with the Equal Employment Opportunity and Equal Opportunity requirements of the contract. The Department also monitors DBE participation as well as the On the Job Training requirements if applicable.


Who is selected for Contract Compliance Review?


• Contractors performing work on multiple or large volume contracts
• Contracts located in areas with high minority and female labor forces
• Contractors who have had compliance issues
• Projects with the greatest potential for employment and contracting opportunities
• Projects with Training Provisions
• Contractors who fail to cooperate with the request for compliance documents


Contract Compliance Reviews:

The review process is used to determine whether firms performing work on ODOT contracts are in compliance with the required Equal Opportunity and Equal Employment Opportunity requirements of the contract. The review process consists of the following components: Planning, Preliminary Analysis, On-site Verification, Compliance Determination and where necessary, Corrective Action.


How do I make a good-faith effort to stay in Compliance?

A contractor is considered to have met its Equal Opportunity and Equal Employment Opportunity Program obligations if there is adequate documented evidence that it made every good-faith effort. If there is evidence of discrimination or a failure to provide Equal Opportunity, the contractor will submit a Corrective Action Plan. If there is no a good-faith effort; evidence of discrimination; or a failure to provide Equal Opportunity, the contractor will submit a Corrective Action Plan. The following criteria will be considered in determining if a firm has made a good-faith effort:


• Contractor’s EEO Policy
• Dissemination of the EEO Policy
• Authority and Responsibility of EEO Officer
• Periodic EEO meetings
• Notices/poster on the bulletin board including “EEO Is the Law”
• Advertising as “An Equal Employment Opportunity Employer”
• Recruitment (direct recruitment efforts with sources likely to yield minorities and women)
• Educate all supervisors within 30 days of the firm’s affirmative action obligations
• Encourage present employees to refer women and minorities
• Evaluate wages to determine if discrimination exists
• Investigation of all complaints
• Assist in locating, qualifying and increasing the skills of minorities and women
• Uses training programs and advises employees and applicants of opportunities
• Minorities and women exist in contractor’s training program
• Ensure non-segregated facilities
• Minorities and women are employed in all occupations, crafts and job classifications on an equal basis
• Procedures establishing the monitoring of subcontractors’ compliance with nondiscrimination
• EO and EEO procedures
• Adequate records and reports
• Minorities and women reach accumulating work hours expected based on their representation
• Written notices have been sent to unions (contractors’ signatory to union agreements are required to use their best efforts to incorporate an EEO clause into each union agreement pursuant to 23 CFR 2320, Subpart A, Appendix A). The contractors shall notify the union(s) of their commitment to EEO
• The EEO officer representing the contractor understands their role and responsibilities
• The EEO clauses are included in purchase orders, subcontracts, and collective bargaining agreements


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