In addition to detailing it’s definition of a systemic discrimination case, OFCCP’s 2014 budget justification document also confirms the Agency’s intent to implement an enterprise-wide investigative process (as opposed to focusing on individual establishments). In its budget justification document OFCCP states that focusing on identifying issues across multiple facilities will ensure that corporate-wide changes in personnel practices are implemented, when necessary, throughout the contractor’s entire corporate structure, and not just within the facility that is the subject of the initial OFCCP investigation.  With this admitted shifted in focus, employers need to be mindful of their enterprise-wide practices (employment testing, compensation practices, use of criminal background checks) and the potential compliance pitfalls associated with these practices.