In July 2025, the Department of Labor (DOL) announced it reinstated and updated self-audit programs run by its agencies, including the reimplementation of the Wage and Hour Division’s Payroll Audit Independent Determination (PAID) Program and expansions to the Occupational Safety and Health Administration (OSHA)’s On-Site Consultation and Voluntary Protection Programs. The efforts to update some programs follow legislation introduced earlier this year intended to codify Voluntary Protection Programs into law.

DOL self-audit programs
The Wage and Hour Division (WHD) restarted the PAID program, a self-audit initiative originally introduced in the first Trump administration to reduce regulatory burdens for employers and promote voluntary compliance with wage laws. Under the program, employers may voluntarily conduct self-audits to correct payroll errors related to minimum wage or overtime violations under the Fair Labor Standards Act (FLSA), as well as certain violations under the Family and Medical Leave Act (FMLA). Accepted applicants to the program can give employees back wages or other necessary remedies under the supervision of the WHD without the risk of employer and employee litigation or arbitration.

Additionally, OSHA is expanding its Voluntary Protection Programs (VPPs) and increasing its efforts to promote voluntary compliance through its On-Site Consultation Program.

OSHA’s VPPs are programs designed to exempt employers from programmed OSHA inspections if they undergo rigorous self-evaluations. To qualify, employers must implement safety measures to control hazards, demonstrate injury and illness rates significantly below national averages and commit to continuous improvement. Under the program, employers are exempt from routine OSHA inspections if work sites successfully pass the program’s on-site evaluation, but they must continue annual self-evaluations.

Similarly, OSHA’s On-Site Consultation Program provides small and midsize businesses an opportunity to receive free, confidential help from OSHA consultants to identify and eliminate workplace safety and health hazards, improve safety practices and programs and train employees in workplace safety. Employer participation in the program does not trigger OSHA enforcement, and identified violations are generally not reported to OSHA inspection staff as long as they are addressed within a certain amount of time.

Overall, the DOL’s initiation of this self-audit campaign demonstrates an emphasis on a return to voluntary self-disclosure and the expansion of opportunities for employers to self-evaluate the integrity of their business practices and work sites.

Introduction of Michael Enzi Voluntary Protection Program Act
Earlier this year, the House of Representatives and Senate introduced the Michael Enzi Voluntary Protection Program Act (H.R. 2844/S. 1417). The bill aims to statutorily authorize OSHA’s Voluntary Protection Programs.

The bill includes similar requirements for participation in VPPs that currently exist for such programs. The benefit of codifying the VPP program is that it prevents OSHA from canceling or not funding what is now an “administrative” program. The bill would require OSHA to allocate at least 5% of its annual budget to implement and operate the VPPs
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What is TCIA doing?
In September, TCIA joined a letter from the Coalition for Workplace Safety (CWS) urging members of the House Education & Workforce Committee to approve the legislation. The letter emphasizes the numerous benefits of VPPs, including their cost effectiveness in reducing financial and administrative costs for both the government and employers, statistical evidence demonstrating their success at reducing occupational injuries and illnesses and the collaborative relationships fostered between the employers and OSHA as a result of the programs.

Bailey Graves is a senior associate with Ulman Public Policy, TCIA’s Washington, D.C.-based advocacy and lobbying partner.