Lately, my client roster is filling up with new federal contractors and I have been focused on getting them up to speed on all their new requirements. We focus on the elements of an AAP, recordkeeping, self-ID forms, posters, etc. When we are in the midst of making sure we have dotted every “i” and crossed every “t”, sometimes we lose sight of the bigger picture. Are we working towards creating an inclusive workforce...

Like I said, I am all about technology. It is essential to make your systems work for you instead of fighting to gather and analyze employee data. However, making the move to an HR system for the first time or moving systems isn’t without its issues; therefore, here are a few affirmative action compliance items to keep in mind: recordkeeping requirements, viewing and access to data, what to do with the originals, acce...

In a previous article, we talked about the fact that the OFCCP has tools to answer your questions. So let’s continue that conversation with some more FAQs and tools on some of the most asked-about topics. Section 503 We have all begun collecting data, conducting outreach and analyzing our organizations according the new 503 regulations, but contractors still have a lot of questions, and here are the tools the OFCC...

Conquering the maze of Affirmative Action laws and regulations can be daunting. Okay, it can be overwhelming. But the Office of Federal Contract Compliance Programs (OFCCP) has provided some helpful tools to guide you to the answers you seek. One of my go-to places for answers is, you guessed it, OFCCP’s Frequently Asked Questions. And my most frequently asked questions relate to the Internet Applicant Rec...

This year marks the 10th anniversary of the Office of Federal Contract Compliance Programs’ (OFCCP) Internet Applicant Rule. Hiring violations still top the charts for financial settlements; so it is worth making sure your organization understands and is implementing the rule accurately and consistently. Here are the top three pieces of advice I give to my clients: first, develop basic qualification...

Well a lot. So much has happened that I will skip my usual lengthy yet insightful prose for short, sweet and to the point. Enjoy! Pay Transparency The Office of Federal Contract Compliance Programs (OFCCP) issued a final rule implementing Executive Order 13665 promoting pay transparency, which took effect January 11, 2016. The rule prohibits federal contractors and subcontractors from discriminating again...

Like we said last month, data is the foundation and a necessity to all things AA compliance. And I am sure most of you would agree we have a love/hate relationship with our applicant tracking system (ATS). Managing all of your candidates electronically is so much easier then doing it manually, but there is a constant struggle between ease of use by the recruiter, simple process for the candidate and getting all the inform...

Data is the foundation and a necessity to all things AA compliance. It can be something you get easily or it can become the bane of your AA existence. What is the difference between getting that data easily and it becoming a struggle? Technology. Now I don’t mean you have to have cutting edge systems with all the bells and whistles, but you must understand the capabilities of the systems you do have and create processes...

Beginning in January 2011, OFCCP implemented its new audit strategy that moved the philosophy of compliance evaluations from management to enforcement. Director Shiu discontinued the previous compliance evaluation strategy of Active Case Management (ACM) and rang in the new year with a new directive, Active Case Enforcement (ACE). The switch to ACE is part of the OFCCP’s plan to continually increase efforts to enforce...

In June, the OFCCP released a new directive outlining updates to the FAAP process. According to Director Patricia Shiu, “the FAAP is back and is better than before.” Below are excerpts from the OFCCP’s Functional Affirmative Action Program (FAAP) FAQs. Click here to read the full version. What is a Functional Affirmative Action Program? Each covered non-construction contractor must develop and maintain an...