1. Presentation Title
Date/Conference/Whatever

2. OFCCP

3. What is the OFCCP?
• Office of Federal Contract Compliance Programs (OFCCP)
• Unit within the Department of Labor (DOL)
• Not the Equal Employment Opportunity Commission (EEOC)
• Conducts compliance reviews of companies covered by federal regulations
• Examines hiring, promotion, retention, compensation practices

4. Data Collection

5. New data collection and how you need to collect it
• The number of applicants who self-identified as individuals with disabilities...or who
are otherwise known to be individuals with disabilities;
• The total number of job openings and total number of jobs filled;
• The total number of applicants for all jobs;
• The number of applicants with disabilities hired; and
• The total number of applicants hired.
• In order to comply with this the contractor will have to have EVERY applicant fill out a
disclosure form similar to the EEOC form The new form, found here:
http://www.dol.gov/ofccp/regs/compliance/sec503/Voluntary_Self-Iden...

6. Job Posting Changes
• The OFCCP has also expanded the requirement that contractors alert job seekers
that they will not be discriminated against on the basis of race and gender to include
disability and veteran status.
• New Tag Line Language for Job Advertisements:
• "We are an equal opportunity employer and all qualified applicants will receive
consideration for employment without regard to race, color, religion, sex, national
origin, disability status, protected veteran status, or any other characteristic protected
by law."

7. Veterans and Disabled

8. Outreach to Find Veterans and Individuals with
Disabilities
• OFCCP currently requires outreach and documentation of outreach
• New regulations require annual assessment of outreach efforts
• Included in each affirmative action plan update
• Assessment must include review of data collected for three years
• Criteria used to assess effectiveness of outreach must be documented
• If company finds efforts were not effective, must develop action plans
• OFCCP will determine if company’s conclusion regarding outreach was reasonable
• Must send written notification to subcontractors, vendors, and suppliers
• Must undertake “appropriate outreach and positive recruitment activities”
• No specific recruitment sources required

9. Using Third Parties

10. Using Third Parties and the Employment Service
Delivery Systems
• Can use “a privately run job service or exchange” if service provides
information to employment service delivery system in manner and
format permitted by employment service delivery system
• When third parties are used to list openings, federal contractors or
subcontractors must provide employment service delivery system
offices with contact information for the third party
• Disclosure must be made simultaneously with first listing with
employment service delivery systems
• For larger multi-state employers, there may be extensive updates
required with employment service delivery systems

11. Third Party Compliance Checklist
• Register employment service delivery system account(s)
• Provide employment service delivery system offices with contact information for the
third party and person responsible for hiring at location
• Must provide name and location of each hiring location within the state
• Post open positions onto the employment service delivery system in an acceptable
format
• Record/document the posting with a confirmation ID from the employment service
delivery system
• Save PDF snapshots of the job postings
• Collect demographic data
• Record searches in the resume database
• Verify job websites allow Internet accessibility for individuals with disabilities
• Send your jobs to organizations within the community for women, minorities,
individuals with disabilities, and veterans

12. Outreach

13. Specific Outreach Efforts
• Revised regulations list examples of outreach activities
• Local veterans employment representative (LVER)
• Disabled veterans outreach program (DVOP)
• Department of Veterans Affairs (DVA)
• Transition Assistance Program (TAP)
• Local veterans groups
• Veterans representatives on college campuses
• State vocational rehabilitation agencies
• Department of Veterans Affairs (DVA)
• Employer Assistance and Resource Network (EARN)
• Local disability groups

14. Outreach Efforts and Documentation
• Revised regulations encourage establishing relationships
• Hold formal briefings with representatives of recruiting sources, including facility tours
• Meet with educational institutionns regarding recruitment efforts
• Participate in work-study programs
• Must have specific documentation of outreach activities
• Review documentation as part of assessment of outreach

15. Top Things to Do Now

16. Top Things to Do Now
• Begin revising AAPs to meet new requirements
• Develop strategies to meet goal for persons with disabilities and benchmark for
veterans
• Develop data collection processes
• Work with systems vendors and HR staff to determine how new invitations to identify
will be used
• Track and determine effectiveness of referral sources
• Incorporate new equal opportunity clauses into subcontracts and purchase orders
• Revise policy statements
• Include new EEO tagline in job postings
• Provide employees with notice regarding provisions of AAPs
• Determine how jobs with be listed with employment service delivery system offices

17. Derek Zeller
Derek@DerDiver.com
www.DerDiver.com
Phone Number?