CAI’s Manager for Affirmative Action Services, Kaleigh Ferraro, shares information on affirmative action plans from the OFCCP. Make sure you are compliant.
On September 30, 2014, the Office of Federal Contracts Compliance Programs (OFCCP) released an updated audit Scheduling Letter. The OFCCP indicated they would begin issuing a new audit scheduling letter on October 15, 2014 for contractor audits. Outlined below are the significant changes from the previous scheduling letter and itemized listing and the newly approved one.
- The Itemized listing requires companies to submit 22 items versus the 11 previously required.
- Employment Activity data (applicants, hires, promotions, terminations) must be submitted including race subgroups not just minority totals. Information on applicants with “unknown” race and gender must also be included.
- Compensation data must be submitted at the employee level and not aggregated as previously required. Data for all employees includes: race, gender, hire date, job title, EEO-1 category, job group, hours worked, base pay or rate plus additional compensation such as bonuses, commissions, merit pay, etc. Compensation date should be submitted electronically.
- Copies of reasonable accommodation policies, requests and resolutions.
The revised scheduling letter and itemized listing also incorporates new items related to the revised regulations for Section 503 of the Rehabilitation Act and Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA). This newly requested information includes:
- Evaluation results of effectiveness of outreach and recruitment efforts for individuals with disabilities and protected veterans.
- Documentation of actions taken to comply with audit and reporting system requirements.
- Submittal of data collected regarding number of applicants, applicants who identified as veterans or individuals with disabilities, number of hires and those that identified as veterans or disabled and job openings and jobs filled.
- Documentation on hiring benchmarks for veterans and analysis on utilization goals for individuals with disabilities. Results of most recent assessments on personnel processes, including date performed, actions taken and date of next scheduled assessment.
- Recent assessments of physical and mental qualifications, including date performed, actions taken and date of next scheduled assessment.
Contractors should review the revised Scheduling Letter as well as their affirmative action program and data to ensure they are properly capturing and maintaining requested information. Contractors only have 30 days from receipt of the letter to gather and submit the requested information.
For more information on affirmative action and the recent changes within it, please be sure to sign up for our free webinar Affirmative Action 101: The Basics on December 2, 2014.
For helpful tips and information on preparing your next affirmative action plan, please sign up for our next affirmative action class AAP: What it Takes To Prepare a Compliant Affirmative Action Plan on December, 12, 2014.