In depth affirmative action 5
What every federal contractor should do, right now:
Update invitations to self-identify for veterans and implement new process for using OFCCP self-identification form for individuals with disabilities. LINK: http://www.dol.gov/ofccp/regs/compliance/sec503/Voluntary_Self-Identification_of_Disability_CC-305_SD_Edit1.24.14.pdf
Train personnel involved in personnel decisions, including recruiting, screening, promotion, reasonable accommodations, on the affirmative action requirements for veterans and individuals with disabilities and document all personnel who attend training.
Develop effective outreach and recruitment sources for veterans and individuals with disabilities.
Review accommodation policies and procedures in light of Final Rules.
Train your HR/recruiters on the process for conducting visual identifications of individuals with disabilities.
Create a process for inviting current employees to self-identify as disabled applicants every five years, including the interim survey in the intervening five years.
Develop written reports analyzing outreach and recruitment efforts and conclusions of those efforts to be completed in conjunction with each affirmative action plan.
Implement process for analyzing hiring benchmarks for veterans and utilization goals for individuals with disabilities in each affirmative action plan and design effective audit and reporting systems for taking remedial action if there are areas of underutilization.
Establish a reasonable budget for all your affirmative action efforts .
Remember, attorneys are not doing this for you, no matter how much you want to pay them. A federal contractor is required to assign one individual who will be responsible for the affirmative action plan, its implementation and its annual review regarding its effectiveness.
We certify that you are working with us and through us you are making an effort to reach out to minorities and women…
We will show you how you can post all your job openings, to appear nationally, on veteransjobbank, (NRD.gov) and VetCentral (US.jobs) as well as our over 100 job boards, State Job Boards as well as how to find your careeronestop local resources.
We publish your EEO statement, thus covering the required mandate to externally disseminate your policy statement.
We provide you with outreach solutions to individuals with disabilities, veterans and minorities.. with over 60 websites that you need to sign up with, engage with and show your good faith efforts.
We post an active link on MSPG.org, to cover the linkage requirement, you need to link back to us.
Nobody can do this for you, there are certain things that you must do in order to stay in compliance. We will show you the record keeping requirements as well as the DOL forms you need to utilize.
We keep you updated on Affirmative Action requirements, changes and new information, as they occur.
We will also show you what will be expected of you in an audit.
We narrow it down to a manageable level to help you to stay in compliance.
The effort is more important than achieving the goals. Our Road Map to compliance will show you how and where to make those efforts.
We cover :
Page 58, Desk Audit / 43
b Goal Areas Needing Further Examination for Good Faith Efforts.
What AAP commitments did the contractor make about recruitment efforts? Is there any evidence they were fulfilled?
Was there an adequate representation of minorities and women in probable feeder groups if the contractor filled jobs primarily by promotion?
What AAP commitments did the contractor make concerning the promotion process (e.g., job postings… ) …..?
Page 85, Onsite Review | 70
2E02 –Evaluation of Good Faith Efforts
b. Good Faith Efforts – External Placements….
Recruiting sources in the AAP. Does the contractor use the recruitment sources listed in its AAP to reach out to minorities and women? If so, when and how?
Using Other Recruitment Sources. Does the contractor use other recruitment sources that are not listed in its AAP to reach out to minorities and women?
Using the Media. How are job openings advertised? Does the contractor advertise in publications or other media that are targeted to minorities and women? If so, which ones?
Page 89, Onsite Review | 74
2E03 Audit of Employment Activity to Ensure Equal Employment Opportunity
f. Disseminate EEO Policy Externally and Perform Outreach and Positive Recruitment. COs must verify during the onsite review that the contractor engaged in outreach and positive recruitment activities. To do this, COs must conduct interviews with contractor officials and third party organizations regarding outreach and recruitment efforts.
Page 93, Onsite Review | 78
2G Religion and National Origin Requirements
2G00 Contractor Policy Implementation
Second paragraph, .. A CO will also verify that the contractor has participated in recruitment and outreach efforts….. COs must obtain documentation regarding recruitment and outreach, and other affirmative action efforts.
Page 121, Onsite Review | 106
2M01 Management Interviews
last bullet point: Is the contractor making efforts to reach out to or establish linkages with groups representing veterans, individuals with disabilities, women and minorities? Describe those efforts.
Every federal contractor is required to post their job openings with their State’s job bank/website.. that is one step. However, the requirement for good faith efforts is not met with this one step. Always do more than is absolutely necessary. Posting with MSPG.org will lend tremendous credibility to your good faith efforts, as our career site appears on over 100 job boards nationwide.
There is no “One Stop Shop” for your affirmative action obligations. Your written affirmative action plan can not just consist of the name of one company, no matter how much you pay them, no matter if they are attorneys or not. If your entire effort is the name of just one company, then, obviously, you are not making an effort. There is a difference between trying to be in compliance, passing an audit and being in compliance with your good faith effort requirements. You are also required to be able to “describe” your good faith effort as well as your efforts in outreach. Can you describe your efforts?
Let us help you and show you where and how you can make the effort.
Our Road Map to Compliance includes the following information:
- Easy to understand and implement (no legal jargon)
- Details of a compliance review and desk audit
- Resources from the DOL and OFCCP to be included in your AAP
- List of compliance requirements, record keeping, DOL forms
- Required State job boards, Career-One-Stop centers and others
- Additional websites for outreach to individuals with disabilities
- Additioanl websites for outreach to veterans
- Additional websites for outreach to minorities and women
- How to post your job openings on exchange websites at no cost
- Employer resources with NRD, minority colleges and others
- How to search the FCCM without reading 536 pages
- How to prepare for an audit
- EEO policy from the EEOC
- Over 60 websites that should be part of your AAP
- Important links to VEVRAA, Section 503 and FAQs from the DOL
- Explanation of the FCCM