Understanding Item 19's "Other Compensation"
OFCCP's Item 19's "Other Compensation" submission requirements has been throwing many contractors[...]
By: Recruiting Specialist
Start by updating your Affirmative Action Plan and make sure to identify yourself as a federal contractor on your Employment Service Delivery Systems as you post your jobs. Similarly, update source codes in your applicant tracking system and create user accounts in every state you post jobs.
As self-identification of candidates as veterans and disabled is now encouraged by the OFCCP you should first conduct an initial self-identification survey of employees. Then, during the application process invite applicants to voluntarily self-identify as a person with a disability or as a veteran, at the pre- and post-offer stages, using the OFCCP form.
Make sure to include an EO policy statement in the AAP that shows top executive support for your AAPs. Also it is crucial to ensure that applicants and employees with disabilities have equal access to the contractors' personnel processes, including those implemented, using electronic means.
No outreach is meaningful unless it is evaluated periodically for effectiveness so assess and document the effectiveness of your outreach and recruitment efforts annually and ensure that outreach and recruitment records are retained for three years. Remember to document actions taken to comply with the audit and reporting system obligations.
As everyone in the company needs to be on the same page, you need to train employees engaged in key personnel activities so they are following company policies aligned with the new regulations uniformly. Conduct data analysis by calculating data related to applicants and hires and carry out an annual workforce assessment and apply the 7 percent goal to each job group or to the workforce as a whole if you are a contractor with 100 employees or fewer.
Most importantly, develop action plans for resolving any problems identified in your utilization of individuals with disabilities. The 7% goal will be strictly enforced and if not reached very concrete outreach steps and analysis of gaps have to be demonstrated.For more information:
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