Many of our Members are on calendar year Affirmative Action Programs. By now (hopefully), most of you have reviewed your 2018 data, and in some cases, you may be establishing your action-oriented programs for areas where you have placement goals. As you analyze what worked and what didn’t work last year, keep in mind the additional outreach efforts and reviews required under Section 503 and VEVRAA.
Executive Order 11246 requires action-oriented programs aimed at increasing your employment population of women and minorities. Outreach and positive recruitment is one way to do this, but keep in mind that this is not the only way. Review your current employment practices. Is everyone given an equal opportunity to receive training and apply for promotions? Are you conducting exit interviews? You could do a great job at diverse hiring, but what if these individuals leave at the same rate they come in?
Section 503 also requires action-oriented programs, in addition to outreach and positive recruitment. Outreach and positive recruitment does not mean posting your job openings, crossing your fingers, and hoping that individuals with disabilities apply! The intent is that you actively put forth the effort to network, build relationships and talk to people about your company and your open positions. Document all of these efforts! Explore ideas and recommendations for reasonable accommodations. With Focused Reviews, the expectation (and requirement) is that you do more than just post jobs and hope individuals with disabilities find them.
VEVRAA requires listing your jobs with the employment service delivery system, or more commonly referred to as CareerOneStop Centers, for compliance. DirectEmployers does this for you, allowing you to check the box for your listing requirement. However, it alone does not constitute outreach and positive recruitment. Utilizing the VetCentral Direct tool is one way to engage in positive recruitment efforts with the CareerOneStop Centers. Through this platform, you can capture your interactions with various employment specialists at the CareerOneStop Centers. Building relationships and sharing your employment needs is what outreach is all about.
We are here to help and have built tools to assist in documenting and analyzing your recruitment efforts. If your company is not utilizing the Partner Relationship Manager or VetCentral Direct, now is the time to take action! Talent Acquisition teams, a best practice is to hold Recruiters accountable for their outreach efforts! Do quarterly reviews to talk about relationships developed, what has worked, and what new avenues you should explore.
Get to know our partners! We distribute your jobs through the syndicated job alliances, allowing for the introduction of your company and openings, but you need to reach out, follow-up and build that relationship! Talk to fellow Members! Are you looking for resources that have been successful for other Members in related industries or locations? Log into the DE Connect Community and talk about it! Better yet, correspond in person at DEAM19!
|AAP||Regulation||Specific Section (emphasis added)|
|EO 11246 (Women & Minorities)||§60 -2.17 Additional required elements of affirmative action programs.||(c)Action-oriented programs. The contractor must develop and execute action-oriented programs designed to correct any problem areas identified pursuant to §60-2.17(b) and to attain established goals and objectives. In order for these action-oriented programs to be effective, the contractor must ensure that they consist of more than following the same procedures which have previously produced inadequate results. Furthermore, a contractor must demonstrate that it has made good faith efforts to remove identified barriers, expand employment opportunities, and produce measurable results.|
|Section 503 (Individuals with Disabilities)||§60-741.44 Required contents of affirmative action programs.||(f)(1)(i) Required outreach efforts. The contractor shall undertake appropriate outreach and positive recruitment activities such as those listed in paragraph (f)(2) of this section that are reasonably designed to effectively recruit qualified individuals with disabilities.|
|VEVRAA (Protected Veterans)||§60-300.44 Required contents of affirmative action programs.||(f)(1)(i) Required outreach efforts. The contractor shall undertake appropriate outreach and positive recruitment activities such as those listed in paragraph (f)(2) of this section that are reasonably designed to effectively recruit protected veterans.|
|Both VEVRAA & Section 503||(f)(3) Assessment of external outreach and recruitment efforts. The contractor shall, on an annual basis, review the outreach and recruitment efforts it has taken over the previous twelve months to evaluate their effectiveness in identifying and recruiting qualified protected veterans. The contractor shall document each evaluation, including at a minimum the criteria it used to evaluate the effectiveness of each effort and the contractor’s conclusion as to whether each effort was effective. Among these criteria shall be the data collected pursuant to paragraph (k) of this section for the current year and the two most recent previous years. The contractor’s conclusion as to the effectiveness of its outreach efforts must be reasonable as determined by OFCCP in light of these regulations. If the contractor concludes the totality of its efforts were not effective in identifying and recruiting qualified protected veterans, it shall identify and implement alternative efforts listed in paragraphs (f)(1) or (f)(2) of this section in order to fulfill its obligations.|
Jennifer Polcer, PHR, SHRM-CP, is the VP of Compliance at DirectEmployers Association where she looks to be a resource to Members providing guidance on compliance matters related to Affirmative Action, audit advocacy and additional education surrounding government contractor obligations. Full Bio »