10 things to do NOW to stay compliant with OFCCP regs

by Terri Swain

Here Are Our 10 Tips For Staying Compliant With OFCCP Regulations: 

  1. Talk To Your Business Development Department, Procurement Department Or Other Key Sales People In Your Organization To Determine If You Are A Federal Government Contractor Or Subcontractor.  We’re Encountering Many Situations Where An Audit Letter Was The First Notice For HR Or Legal That The Company Had Entered The Affirmative Action Space.
  2. Keep Your Plan Up To Date.  An Affirmative Action Plan Is An Annual Process. Be Disciplined About Putting It Together, On Time.
  3. Review All Data For Accuracy. Pay Close Attention To Race, Gender, And Job Titles To Assure They Are Accurate.
  4. Conduct Adverse Impact Analyses On Applicant Flow/Hires; Promotions And Terminations. If There Is Any Adverse Impact, Make Sure The Data Sets Are Correct. Go Back And Investigate Why Potential Adverse Impact Is Occurring.
  5. Make Sure You Are Defining “Applicant” Properly And Recognize That Less Is More When It Comes To Applicants.
  6. Share Your Results With Your Management Team. They Don’t Need To Know All The Details Of The Statistics, But They Do Need To Know Areas Of Underutilization.
  7. Make Sure Your Career Page From Your Company Website Gives An Alternate Method To Apply For Those Who Can’t Use The On-Line System Due To Disabilities.
  8. DEVELOP STRATEGIES FOR GOOD FAITH EFFORTS For Females, Minorities, Disabled And Veterans.  Document.  Your Audit Will Focus On This – Especially Veteran’s And Disability Resources.  Consider Meaningful Ones For Your Business Vs. Check The Box.
  9. Post All Your Jobs With Your State Job Service.  They Will Check.
  10. Regularly Review Compensation Equity For Similarly Situated Employees. Be Able To Explain Differences In Pay Between People – Is Your System Seniority Driven? Performance Driven? Skill Driven? Experience Driven? Do You Have The Back Up Documentation?

The OFCCP Is Changing And Aggressively Reviewing Your Employment Practices.  The Best Defense Is Always A Good Offense. Make Sure Your Are On Top Of Your Compliance Documents, Outreach Requirements And Employment Decision Documentation.