People consistently ask BCG "Why is OFCCP asking me for this?" Of course "this" may be a number of different things, but recently OFCCP has been rolling out new expectations as part of their latest audit push so we wanted to give people an idea what to expect going into 2009.
The bottom line, is that while OFCCP is still making most of their money on recordkeeping and adverse impact violations, they are still forging ahead into new territory on many new directives that are causing uncertainty in the contractor community.
One concern in-particular that we are seeing in almost every new audit is OFCCP asking for not only the structure of how the contractor is posting jobs, but for what Veterans Groups they are posting to, who is their contact and most importantly what the results of the postings are. Requesting details on the number of Veterans who applied is a new request. Whether OFCCP has the right to require this information is currently under debate. However, that has not stopped OFCCP from requesting the data in writing during a desk-audit.
Also, OFCCP is now reviewing the contractor's Applicant Tracking System to determine if there are any barriers that Veterans or the Disabled may face when applying for a job online. If there are perceived barriers, then an on-site visit might be triggered. There is a link below to the OFCCP Applicant Systems Directive in addition to a link on OFCCP resources that all contractors should bookmark.
Directory:
http://www.dol.gov/esa/ofccp/sitenavi.htm
Applicant Systems Directive:
http://www.dol.gov/esa/ofccp/regs/compliance/directives/dir281.htm
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