For 16 years, I led the Logistics Division of Walgreens that included more than 10,000 employees and 17 distribution centers across the country. I am also the father of two daughters and a 28-year-old son with autism. As might be expected, I am more proud of the latter than any...more
In my last article for the The OFCCP Digest, I wrote about the changing perceptions of race, ethnicity, and gender, and how these changes may affect regulatory compliance. For federal contractors and subcontractors, there are two remaining classes that are protected under...more
Oh oh, EEOC has just asked you for a list of names and telephone numbers for a large group of your employees. Why? The usual answer is because EEOC wants to interview at least some of them to see if they have evidence supporting the claims in a discrimination charge filed by...more
Applicant disposition codes are one factor that can potentially “make or break” Affirmative Action Plan (AAP) data. As a best practice, we recommend having detailed disposition codes that include two pieces of information for each candidate – the step and status...more
Lately, my client roster is filling up with new federal contractors and I have been focused on getting them up to speed on all their new requirements. We focus on the elements of an AAP, recordkeeping, self-ID forms, posters, etc. When we are in the midst of making sure we...more
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. Questions and answers will occasionally be featured in The OFCCP Digest for the benefit of all readers.
Question: Staffing Agency Letter
I understand that we have obligations to notify staffing agencies about our federal contractor status, but what does that notification really ask? Are we putting them on alert that they need to send us diverse candidate pools, are we notifying them that they may have obligations as a sub-contractor or are we just satisfying a regulation? I send these letters out annually and don't really see the benefit other than we are meeting our compliance requirement. Can someone please explain the rule?
The purpose behind the rule is to ensure that the staffing agencies are keeping you compliant. As your sub-contractor, they need to be conducting outreach according to the federal contractor regulations. The notice itself is not the most critical issue. As a federal contractor, it is your obligation to ensure that the staffing agency is following the regulations, as though you were conducting the outreach for yourself.
EEOC Conducting New Training on Harassment Prevention
Read more DOL Highlights throughout the month for timely updates.
The OFCCP Digest is a complimentary resource featuring affirmative action, equal employment opportunity, and government compliance topics. Previous editions are available for easy reference on The OFCCP Digest Archives page. To subscribe or to provide feedback, email OFCCPDigest@LocalJobNetwork.com.
The opinions expressed in this newsletter are the opinions of the individual author(s) and do not necessarily reflect the opinions of the Local JobNetwork™. The information appearing in this newsletter is meant to provide the reader with a general understanding of topics relating to OFCCP compliance requirements and is not legal advice. If you are seeking legal advice to address OFCCP compliance issues or requirements, you should consult an attorney. The Local JobNetwork™ expressly disclaims all liability with respect to actions taken or not taken based on any or all of the contents of this newsletter.