ASK THE EXPERT: OFCCP Audits

This is a first, in a series, of ‘Ask The Expert’ Q&A blogs where we will tap into the vast pool of industry knowledge we have here at America’s Job Exchange (AJE). This blog features our resident expert, Gary Cowan, Director of Compliance.

Q: I know you are an expert in your field, but can you give others a quick summary of why you are particularly knowledgeable in the area of OFCCP audits?

A: I worked at the US Department of Labor for over 24 years, 16 years as an investigator and 8 years in the Administration of DOL. During my time as an investigator I trained hundreds of investigators in investigative techniques and the application of the regulations. I also spent 8 years in Boston, NY and DC as a Director of Administration, supervising over 50 staff members, coordinating several national special projects and working with regional directors nationwide.

Q: How do you use your expertise to assist our customers here at AJE?

A: I have the unique experience that I have trained the auditors in investigative techniques, the application of regulations and the inner workings on how and why companies are audited. Providing that information to our customers is extremely valuable in their approach to an OFCCP audit.
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AJE Hosts Another Successful Webinar: A Comprehensive Outreach Plan for OFCCP Compliance

On February 23, 2016, America’s Job Exchange (AJE) co-hosted a webinar with Jackson Lewis on ‘A Comprehensive Outreach Plan for OFCCP Compliance.’ The webinar was very well received with more than 600 in attendance and there were several important and relevant questions posed to the panelists.

Laura Mitchell, Partner, Jackson Lewis, and Gary Cowan, Director of Compliance, America’s Job Exchange (AJE), were the speakers and they covered two important topics:

  • Effective veteran outreach for OFCCP compliance and
  • AJE’s Outreach Management System – a tool available for customers to record outreach activities easily and in a central location

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AJE’s Updated Reporting Tool with an Outreach Management Component

The Office Of Federal Contract Compliance Programs (OFCCP) expects good faith outreach efforts pertaining to affirmative action to be expansive to increase the pool of qualified candidates. Outreach has to be external (to reach the wider labor market), and internal (immediate workforce). Proof of outreach must be meticulously maintained. Good faith efforts also encompass training and promotion of the internal workforce. Results of these efforts also need to be documented and stored for three years in case of an OFCCP audit. Federal contractors and sub-contractors are required to set hiring goals for protected veterans (7%) and utilization goal for Individuals with Disabilities (7%) in all job groups. Additionally, they need to set goals under EO 11246 as applicable. Continue reading