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Review Your OFCCP Compliance Policy

By: Recruiting Specialist

Review Your OFCCP Compliance Policy

The role of the Office of Federal Contract Compliance Programs (OFCCP) is to assess how contractors doing business with the federal government take affirmative action because it relates to equal employment access and non-discrimination. If you are a federal contractor, it is imperative that you review all the elements of OFCCP compliance on a regular basis. Here are steps you should take:

Review your Affirmative Action Plan (AAP)
Make sure that your executives and hiring managers are well–versed and participate in affirmative action and equal opportunity hiring practices. For a compliance strategy to be effective, your AAP should be developed, communicated and implemented by any and all employees involved in hiring. Use your AAP annually to engage in adverse data analysis and document all your outreach efforts.

Review your job posting and reporting strategies
Are you complying with job posting and reporting requirements mandated by the OFCCP? Job posting requirements are at the core of meeting compliance parameters. You are required to make job openings available to state agencies and other employment service delivery systems that reach protected veterans under VEVRAA, and others with minority status, so that they have priority access to job listings. You also need to maintain data on job postings for three years, and submit reports as required.

Review the laws governing OFCCP
Do you know which laws govern OFCCP? Multiple laws have been enacted which impact affirmative action and EEO hiring, including the Rehabilitation Act, of which Section 503 requires affirmative action for individuals with disabilities and has been recently updated. Another, the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA), which was enacted in 1974 and also has been revised recently, mandates that those doing business with the government ensure their job openings reach qualified veterans returning home and that there is no discrimination in the hiring process. Both these regulations have been recently revised and been made more stringent. If you and your staff are not familiar with these and other laws governing OFCCP requirements, make sure to be now!

Review your preparedness for the OFCCP audit process
Are you ready if you receive a Scheduling Letter? During an OFCCP audit you will be required to submit hiring data, including internal records related to your hiring practices without any resistance. This includes, and is not limited to compensation data, personnel files, and other policies and procedures. Be ready to be audited at any time and understand the elements of the audit process. Being well prepared in advance of any audit can help you respond and move the process along.

Below are important considerations in order to be fully compliant and ready for an OFCCP audit:

  • Have an accurate organizational profile- Your workforce analysis must show for each unit: total number of males, females, minorities, and the job title, gender, race & ethnicity of the supervisor.
  • Job Group Analysis- Put every job title into a group with other job titles which have similar duties, salary, promotional opportunities, etc. State the percentage of minorities and women in each job group.
  • Availability Analysis for each job group- Have an estimate of the number of qualified minority, women, veteran and disabled candidates available for recruitment (external) and a separate determination of those within your company who are promotable, transferable, or trainable (internal).
  • Utilization Analysis – Make a comparison of the percentage of minorities, women and employees with disabilities currently employed in each job group with those available externally and internally. This will identify any job groups in which you might be underutilized (i.e. have significantly fewer minorities, women and employees with disabilities than are available).
  • AAP Designee- Designate a person responsible for your Affirmative Action Program.
  • Problem Areas- identify problem areas in review of utilization analysis, personnel activity, compensation systems, etc.
  • Action Oriented Programs- create specific programs designed to correct problem areas.
  • Periodic Internal Audits- These must be conducted to measure effectiveness of your AAP. We recommend quarterly reviews of all personnel activity.
  • Document, document, document to demonstrate compliance and save for three years.
  • Post jobs with the appropriate employment service delivery system except senior management positions. Appropriate systems include local employment service offices and state workforce agency job banks.
  • Contact local minority, women, disabled, and veteran associations
  • Maintain EEO-1 Reports (3 years) and VETS-100 (1 year)
  • Ensure accessibility for individuals with disabilities: parking and entrance, restrooms, application computers/kiosks
  • Review EEO policy with all employees
  • Post EEO Policy statements
  • Have thorough salary analysis

For more information on OFCCP compliance, to post jobs that reach diversity candidates or to read about other compliance issues, visit us today at

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