OFCCP Ask the Experts
Ask the Experts is an online forum where federal contractors and subcontractors are invited to submit questions to industry experts related to OFCCP compliance, affirmative action planning, and equal employment opportunity. Simply register your company on LocalJobNetwork.com to submit a question.
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  • Asked by Anonymous - Apr 01, 2019
    As a federal contractor, do we have to display a notice for our employees informing them that they can view the Vets and IWD AAP?
    Answered by Bill Osterndorf from HR Analytical Services - Apr 08, 2019

    The regulations regarding protected veterans and individuals with disabilities have a provision that reads as follows:


  • Asked by Anonymous - Mar 29, 2019

    1. How do you generally recommend we set up job groupings for a multi-site organization from an EEO-1 perspective?
    2. When we have sites that are less than 50 people I don’t believe we are required to report those statistics. Is that your understanding? Do we need to report that information anywhere?

    Thank you!
    Answered by Bill Osterndorf from HR Analytical Services - Mar 29, 2019
    First things first: if by "How do you generally recommend we set up job groupings" you mean "How do we establish job groups for our federal affirmative action plans?", job groupings should be specific to each individual AAP. OFCCP does not conduct compliance reviews by organization; it conducts compliance reviews by "establishment." The Executive Order 11246 affirmative action plan that is prepared for any given establishment should be specific to that establishment. The narrative should reflect what is occuring at that establishment, and statistical structures devised for the AAP should be specific to that establishment. Since job groups are such a foundational tool for developing other statistical reports that are included in AAPs, it...

  • Asked by Anonymous - Mar 27, 2019
    I'm having difficulty finding out exactly what will be asked for in an OFCCP compliance check. I know that they will request our latest AAP, but is there anything else we should expect? Any guidance is appreciated. Thanks!
    Answered by Bill Osterndorf from HR Analytical Services - Mar 29, 2019
    Actually, OFCCP will NOT ask for your most recent AAP during a compliance check. According to the compliance check letter that OFCCP has on file with the Office of Management and Budget, the agency will ask to see the following items:

    "1. AAP results for the preceding year (41 CFR §§ 60-1.12(b); 60-300.44(f)(4)and 300.80; 60-741.44(f)(4)and 741-80).

    2. Examples of job advertisements, including listings with state employment services (41 CFR § 60-1.12(a), § 60-300.80, and § 60-741.80).

    3. Examples...

  • Asked by Anonymous - Mar 27, 2019
    The 6.4% benchmark for 2018 is based on the national percentage of vets in the civilian labor force. We are able to establish our own benchmark based on data from the BLS (Bureau of Labor Statistics) and the Veterans Employment and Training Administration (VETS/ETA) as well as other factors (I am assuming this can mean geographical) that reflect our unique hiring circumstances. If anyone has their own custom benchmark set up, can you share the resource(s) you used to create the benchmark?
    Answered by Roselle Rogers from Local JobNetwork™ - Apr 23, 2019
    OFCCP recently announced that the new VEVRAA hiring benchmark has decreased to 5.9% effective March 31, 2019....

  • Asked by Anonymous - Mar 25, 2019
    Are we required to survey new hires (at orientation) for Race, Gender, Veteran, and Disability status since we also asked on the application?
    Answered by Ellen Shong-Bergman from Ellen Shong & Associates - Mar 25, 2019
    The instructions for completion of the EEO-1 Report compel employers to report on ALL employees by race/ethnicity and gender. Since the government cannot compel your employees to disclose this information, the employer who doesn’t have it is required to make a “visual identification” of race/ethnicity and gender, a very uncomfortable task for most employers. In my experience most employees will voluntarily disclose this information.

    The problem with the responses the employer receives during PRE-employment is three-fold: 1) Many people simply won’t tell you. Despite an employer’s covenant NOT TO USE this information in making any employment decision – AND YOU MAY NOT! – many job seekers simply don’t believe it. And at least with respect...
    Answered by Marilynn L. Schuyler from Schuyler Affirmative Action Practice - Mar 27, 2019
    On September 24, 2013, the U.S. Department of Labor’s Office of Federal Contract Compliance Programs published a Final Rule in the Federal Register revising the regulations implementing the Vietnam Era Veterans’ Readjustment Assistance Act, as amended (VEVRAA) at 41 CFR Part 60-300 and revising the regulations...

  • Asked by Anonymous - Mar 21, 2019
    Do you have any advice to provide when selecting interview evaluation questions? These questions will act as the interview feedback and ultimately show how we made our hiring decision for each applicant. The hiring manager and recruiter will be required to answer these questions and we are leading toward a yes/no format.
    Answered by Lisa Kaiser from The Kaiser Law Group, PLLC - Apr 24, 2019
    I'm not sure what you mean by "interview evaluation questions," so please add some information in another question or reach out to LJN directly for additional help.

    All questions by the...

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