Compliance Tip posts are quick snippets of advice for federal contractors, provided by a variety of field experts. This week’s tip is from Candee Chambers, SPHR, Sr. CAAP and Vice President of Compliance & Partnerships at DirectEmployers Association.
Today’s OFCCP Compliance Tip: “Engaged Recruitment”
Be prepared in OFCCP audits to provide OFCCP with the list of recruitment sources you have contacted and with which you have built personal, or so-called, “engaged” recruitment relationships. Only sending OFCCP a list of job boards to which you have sent your jobs by merely hitting “Send” on your computer keyboard to launch your jobs announcement will no longer satisfy OFCCP’s outreach obligation that your outreach and recruitment be “positive” and “effective” (see 41 CFR Section 60-300.44(f) [Section 4212] and 41 CFR Section 60-741.44(f) [Section 503]). (We at DE already “hit send” for you when we “list” your jobs with the local ESDS’s in the manner and format each permits. OFCCP believes, and we agree, that no “listing” company, however, no matter how good it is can do “effective outreach,” though. That is a different service entirely). Outreach is more than just marketing your organization through diverse job boards – the OFCCP is now looking for the relationship you have built with each recruitment source to allow each of them to understand the specific and unique qualification requirements of your available jobs. OFCCP believes that these personal and more engaged relationships make you more effective in your search to hire qualified protected veterans and individuals with disabilities.
