1. Proposed Changes in OFCCP Regulations
and
What They Mean for Employers and Job Boards
IAEWS Fall Congress • Hollywood, FL • September 05, 2012
Rathin Sinha
President, America’s Job Exchange
America’s Job Exchange
400 Minuteman Road, Andover, MA 01810
www.americasjobexchange.com

2. Disclaimer
Not a legal advice. The presentation is intended only to stimulate discussions among
job board operators and users relating to the recent developments and proposed
regulatory changes at the Office of Federal Contract Compliance Program (OFCCP).
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3. About OFCCP
The OFCCP enforces regulations relating Equal Employment & Affirmative Action
 Represents the benefits of job seekers and employees
● EO11246 – Equal Employment
● Section 503 - Americans with Disabilities
● VEVRAA/Section 4212 - Protected Veterans
 Audits federal contractors and imposes corrective actions if deficient
● Scheduling Letter, Information Request
● Desk Audits, On-Site Audits,
● Conciliation Agreement, Penalties, Debarment
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4. Recent Changes
The OFCCP has gone through significant changes under the current administration
 Increased Importance
● New leadership – former civil rights attorney
● Budget increase of 35%
● New hires of 200 Compliance Officers (CO)
 Increased Enforcement
● Higher incidents of audits
● Aggressive litigation, Larger penalties
 Strengthening Regulations
● Proposed new regulations
● Submitted revisions to current regulations
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5. Essence of Regulatory Changes
Most of the proposed changes related to recruitment can be grouped in the three
areas:
 Mandatory Job Posting and Outreach
● Mandates specific methods of internet job postings and distribution
● Mandates additional outreach with community based organizations
 Data Collection and Tracking
● Pre-employment data collection for protected groups
● Effectiveness of recruitment efforts by source of candidates
 Analytics
● Analysis of candidate availability and actual hiring, compensation
● Annual review of recruitment efforts relative to goals and benchmarks
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6. Proposed Changes: Protected Veterans
 Requires Specific Recruitment Efforts
● Must engage in certain number of outreach and recruitment programs
● Send job listings to the local employment service offices e.g. 1-stop centers
● Develop and maintain ongoing relationship with local Veterans Representatives
● Enter linkage agreement with listed organizations for recruitment and training
● Consult with Employer Resources Section of the National Resource Directory
 Data Tracking
● Initiate requests to have candidates self identify prior to job offer and collect data
● Track number of referrals from the state employment service delivery systems
● Track ratio of protected veteran referrals to total referrals & maintain data for 5 years
● Establish annual hiring benchmark and conduct annual review of recruitment efforts
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7. Proposed Changes: Individuals with Disabilities
 Requires Specific Recruitment Efforts
● Must engage in a minimum number of outreach and recruitment programs
● Send job listings to the local employment One-Stop Career Center
● Maintain ongoing relationship with local State Vocational Rehabilitation Agency
● Enter linkage agreement with listed organizations for recruitment and training
● Consult with Employer Resources Section of the National Resource Directory
 Data Tracking
● Initiate requests to have candidates self identify prior to job offer and collect data
● Track number of referrals from the state employment service delivery systems
● Track ratio of disability referrals to total referrals & maintain data for 5 years
● Establish 7% as a hiring goal for this group and conduct annual review of progress
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8. Impact of Proposed Changes
Federal Contractors Job Boards
 Cost of Implementation  Delivering Recruitment Results
Direct cost and adminsitrative burden Attracting Veterans and the Disabled
 Effectiveness of Recruitment Methods  Broadeing Job Distribution
Source of candidates by specific efforts Manadatory job listing with State Services
 Burden of Data Collection and Tracking  Tools for Data Tracking and Reporting
Manage and protect data for privacy Tracking of attempted/completed applies
 Complexity/Inconsistency of Rules  Support and Consultation
Individual interpretation of regulations Support for audits with proof of effort
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9. America’s Job Exchange
AJE is a leading provider of recruitment advertising and compliance solutions
 Successor to America’s Job Bank
● Launched on the heels of termination of the AJB
program of DOL
 Destination for Job Seekers/Employers to Connect
● Specializes in the recruitment of diversity
candidates and mid-level jobs
 Leader in OFCCP Compliance for Recruitment
● Specializes in veterans and disability recruitment
outreach and mandatory job listing
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10. Solution for OFCCP Compliance
AJE offers a comprehensive solution to assist employers meet OFCCP Compliance.
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11. AJE Job Posting Outreach Network
Employers Job Boards
AJE Job Network State Job Banks
 AJE National Exchange  Job feed
 AJE Diversity Exchanges • Direct job feed to some individual states
• Veterans , Disability, Diversity • Job feed to states via partner feeds
 AJE State Exchanges  Manual posting
• Job Boards for 50 states • Manually posting jobs on behalf of customer
 AJE Jobs Mobile State Career One Stops
AJE Partner Network  Daily email of new jobs to Career One stop offices near
 Niche Job Boards job location:
• Veterans , Disability, Diversity • Veteran representatives
• Career Counselors
 Aggregators
• Jobs, Salary, Company Info
 Community Based Organizations (CBO)
• Local Chapters of Goodwill, Easter Seals
 Government Sponsored Sites
• VetSuccess, Veterans Job Bank
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12. AJE Job Distribution Tracking
Create reports for the company as a
whole or for specific locations or
subsidiaries.
Detailed outreach and distribution
information, including delivery method
and date and time stamp.
Reports can be saved and exported
to PDF and Excel.
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13. How to Prepare for Change
Employers
 Check if you are a Federal Contractor and Implement a Compliance Program
● Cost of compliance is high but much less than the cost of non-compliance.
 Third Party service providers such as AJE are very efficient solutions
● Reduces total cost of program implementation and the administrative burden
Job Boards
 Be aware of the upcoming changes and cross-check with your business plan
● The race to sign on veterans and individuals with disability is heating up
 Data collection, tracking and analysis are going to be more important than ever
● Tying demographics with applies or referrals are going to be key
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14. Thank You
For more information, please contact:
Rathin Sinha
rsinha@americasjobexchange.com