Posts Tagged ‘Affirmative Action Plans’

AAP: Changes to Veteran Self-Identification Solicitation

Thursday, February 26th, 2015

CAI’s Manager for Affirmative Action Services, Kaleigh Ferraro, shares important information regarding AAP requirements and solicitation of self-identification information from veterans.  Make sure you are compliant.

Kaleigh Ferraro, Manager, Affirmative Action Services

Kaleigh Ferraro, Manager, Affirmative Action Services

On September 25, 2014, the Veterans Employment and Training Service issued a final rule changing the reporting requirements for employers covered under the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA).  This final rule rescinds the VETS-100 report and changes the annual veterans report from VETS-100A to VETS-4212.  This reporting change will allow employers to report on aggregated protected veterans rather than the individual veteran classification.  There will also be the option to report on veteran hires and total hires either by the EEO-1 categories or in total.

Since this changes, federal contractors and subcontractors subject to AAP requirements have been asking how this affects their solicitation of veteran classifications during the hiring process.  Regulation changes to VEVRAA effective in 2014 required contractors to solicit veteran status both pre job offer and post job offer.  The solicitation was different pre-offer versus post-offer.  The pre-offer form requested only for applicants to voluntarily self-id as “protected veteran” while the post-offer form requested individuals to identify as specific veteran classifications.  Since the VETS reporting in 2015 will report on aggregated veteran data, the post-offer requesting specific classifications seemed unnecessary.

The Office of Federal Contract Compliance Programs (OFCCP) responded on January 20, 2015 with guidance regarding the self-identification forms and solicitation.

 

  1. Federal contractors and subcontractors may use the same self-identification form for per-offer and post-offer solicitation during the hiring process. This form will invite applicants to voluntarily self-identify as “protected veteran”. There is no need to request specific veteran classification
  2. Contractors may continue to request specific veteran classification post-job offer if they choose to do so.

 

For more information on affirmative action and the recent changes within it, be sure to sign up now for our FREE one hour webinar AAP: What You Need to Know About Recruiting and Applicant Tracking on March 24, 2015.

Our affirmative action team at CAI is dedicated to helping you with all of your affirmative action needs. Whether it’s designing an AAP plan for your company, doing a full audit on an existing plan, or simply answering a few questions, please contact me directly at 919-713-5241 or kaleigh.ferraro@capital.org.

Q&A: 6 Things You Should Know About Affirmative Action Plans

Thursday, August 28th, 2014

CAI’s Manager for Affirmative Action Services, Kaleigh Ferraro, shares information on affirmative action plans from the OFCCP. Make sure you are compliant.

Kaleigh Ferraro, Manager, Affirmative Action Services

Kaleigh Ferraro, Manager, Affirmative Action Services

If your organization provides goods or services to the federal government either directly or indirectly, you may be subject to affirmative action regulations.  Just in 2014, regulation changes regarding affirmative action programs for protected veterans and individuals with disabilities became effective.  President Obama has also signed several Executive Orders affecting federal contractors.  Is your organization in compliance with these recent and proposed changes?

Q: Are you covered as an affirmative action employer?

A: If you have federal contractors or subcontracts of at least $10,000, you are covered under the affirmative action regulations.

 

Q: What are the affirmative action requirements?

A: One of the main requirements is to annually develop written affirmative action plans if you have federal contracts/subcontracts of $50,000 or more and 50 or more employees. There are a number of other requirements as well.

 

Q: What is the impact of the changes to organizations regarding protected veterans and individuals with disabilities?

A: Some of the major changes that became effective in 2014 require setting hiring benchmarks for veterans and utilization goals for individuals with disabilities.  They also require federal contractors to solicit self-identification of applicants for veteran and disability statuses prior to job offer.

 

Q: What type of data is needed to develop an affirmative action plan?

A: In order to develop an annual affirmative action plan, you will need a current listing of employees.  This employee listing will be used to determine if Placement Goals must be established for women and minorities.  This listing will also be used to determine if utilization goals for individuals with disabilities are met.  Contractors must also review employment decisions for hires, promotions and terminations for the 12 months prior to the employee listing.

 

Q: What is required of affirmative action employers other than the written affirmative action plan?

A: There are a number of additional requirements beyond an affirmative action plan.  These requirements include the following: record keeping requirements, tracking applicant data, annually filing EEO-1/VETS-100A reports, notifying subcontractors & vendors of obligations, specific language in covered purchase orders & subcontracts, listing jobs with state employment service delivery systems, outreach and recruitment efforts, etc.  CAI can provide additional information regarding these and other requirements.

 

Q: What are the recently signed Executive Orders and proposed regulation changes?

A: President Obama has signed several Executive Orders in 2014 that may lead to changes for federal contractors and subcontractors.  They include, establishing higher minimum wages for federal contractors, expanding affirmative action requirements to include gender identity and sexual orientation as protected groups, protect workers from retaliation when discussing pay with other employees.  The OFCCP also issued proposed regulations that would require contractors to submit compensation information annually in an expanded Employer Information Report EEO-1

CAI has a team dedicated to affirmative action and can assist with affirmative action questions.  Please contact Kaleigh Ferraro, Manager of Affirmative Action Services directly at 919-713-5241 or kaleigh.ferraro@capital.org  for additional information or other affirmative action questions.