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  • by Bill Osterndorf - May 17, 2013
    The vendors that provide applicant tracking systems routinely suggest that their systems are “OFCCP compliant.” Yet, federal contractors and subcontractors are frequently cited for record-keeping issues associated with applicant data. How can companies ensure that their applicant tracking systems will help them successfully navigate through an OFCCP review? As a starting point, it is important to note that no applican...
  • by Bill Osterndorf - April 26, 2013
    Much has been written about the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) in the last few years. OFCCP has a number of significant new initiatives, most notably its recent directive regarding the evaluation of compensation data that federal contractors and subcontractors will be asked to provide during compliance reviews. OFCCP has also gone through a number of changes to the manner...
  • by Bill Osterndorf - February 21, 2013
    Limiting the Applicant Data That Is Provided to OFCCP Part 2 - Understanding Special Situations In the first part of this two-part series, we discussed the fact that the applicant data that is provided to the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) is a critical piece of information in any affirmative action compliance review. We discovered that OFCCP’s Internet Applicant...
  • by Bill Osterndorf - January 24, 2013
    Limiting the Applicant Data That Is Provided to OFCCP Part 1 - The Rule Regarding Applicant Data Most of the recent discussion about affirmative action compliance reviews by the U.S. Department of Labor's Office of Federal Contract Compliance Programs (OFCCP) tends to focus on two areas: (1) OFCCP's investigation of possible compensation discrimination by federal contractors and subcontractors, and (2) issues concer...
  • by Bill Osterndorf - October 24, 2012
    Your company has received that dreaded letter from the U.S. Department of Labor's Office of Federal Contract Compliance Programs (OFCCP) indicating that your company has been scheduled for an affirmative action compliance review. After the initial panic has subsided, it is time to consider what you will send to OFCCP in order to comply with the requests in the scheduling letter and itemized listing you've received. While...
  • by Bill Osterndorf - August 17, 2012
    From the advent of the eight-factor analysis, availability analyses have been a central part of all federal affirmative action plans. The U.S. Department of Labor's Office of Federal Contract Compliance Programs (OFCCP) changed from an eight-factor analysis to a two-factor analysis (i.e. an analysis examining only external populations and internal populations that may be able to enter jobs) more than ten years ago. However,...
  • by Bill Osterndorf - July 17, 2012
    As a part of the data collection and record-keeping requirements under the federal government's affirmative action regulations, federal contractors and subcontractors are obligated to collect race/ethnicity and gender information from applicants. Contractors are also required to survey employees for race/ethnicity and gender information as well as veteran and disability status. The U.S. Department of Labor's Office of Federa...
  • by Bill Osterndorf - May 22, 2012
    In the last few years, there have been dramatic changes to the focus points at the U.S. Department of Labor's Office of Federal Contract Compliance Programs (OFCCP). While for many years, OFCCP had little interest in issues concerning veterans and persons with disabilities, these groups are now at the forefront of OFCCP's efforts. We know this is true in part because of the proposed regulations regarding veterans that were...
  • by Bill Osterndorf - April 16, 2012
    Using Applicant Reports to Help Your Company During an OFCCP Review Part 2 of 2 In part 1 of this series, we noted that it's a different world out there for companies going through OFCCP reviews. The U.S. Department of Labor's Office of Federal Contract Compliance Programs (OFCCP) continues to closely examine the hiring of federal contractors and subcontractors to determine whether there is any...
  • by Bill Osterndorf - April 10, 2012
    The Storm Arrives At HR Analytical Services, we have been predicting major changes in the way that the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) would approach affirmative action compliance reviews. We are now seeing evidence of those changes. Among the recent requests that have been made of companies during OFCCP reviews are the following: • Multiple companies have been asked...