Notes from an OFCCP Seminar

No wonder so many were in attendance at a seminar on Monday sponsored by the HR consulting firm Gaucher and Associates in Franklin, MA. I have been hearing from customers a lot that the OFCCP has been ramping up the number of audits. In particular, they are paying specific attention to outreach efforts to the Veterans and the Disabled as well as record keeping practices by the employers regarding those efforts. Here are some of the topics that I thought were critical for every employer to know:

  • Quickly Changing Demographics in the US – In a relatively short period of time America will become a nation where minorities will become the majority. Since 1990 the minority population in the U.S. has risen from 19.7% to 34% in 2008. Therefore, recruiting efforts should take this into account to take advantage of the growing potential our diverse talent pool offers.
  • Candidate Self Identification – Regarding rules on Veterans, Disabled Veterans, and people with disabilities, employers must be careful to ask candidates to self identify at the appropriate time, such as after an employment offer is made, but before the actual start date of employment.
  • Recruiting outreach efforts to Veterans, Disabled Veterans, and the Disabled – It is particularly interesting to note that one reason there is such a big emphasis with OFCCP with regards to Veterans and the Disabled is because there is now statistical data regarding these communities that is being tracked. There are exceptions to VEVRAA requirements, for example, Executive and Senior level positions, but since this topic is gaining increasing visibility, employers are encouraged to make sure they are doing everything they can to attract Veterans and Disabled candidates to their business.
  • Company’s Affirmative Action Plans – To implement an Affirmative Action Plan and compliance strategies for Veterans and the Disabled, businesses must keep detailed records of both internal and external recruiting communications and accommodations made for these specific groups. Companies must also make sure that their internal auditing and reporting systems are tracking all related information.

As an internet recruitment consultant at America’s Job Exchange, my recommendation to all employers would be to pay particular attention to the topics listed above and make sure your business is not only making good faith efforts to reach out to Veterans and the Disabled, but also keeping detailed records of your efforts and activity. At America’s Job Exchange, we help customers in their efforts not only by distributing job postings to the “local employment delivery system,” but also by distributing to partner websites that cater to the Veteran and Disabled Communities as well as to our own Veteran and Disability Exchanges. In addition our customers also get monthly reports of these outreach efforts as proof of their outreach. With the landscape of diversity hiring changing quickly, now is a great time to evaluate your efforts and see if there is anything you can do to enhance them. Leave me a comment if you have any questions about this. I’d be happy to discuss it. Best Regards, Alan Klapman America’s Job Exchange

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