After January 1, the next most popular plan date contractors use is July 1. While our recommendations for pulling your data apply to whatever plan date you have, there are additional considerations for July 1, especially this year. Here are some things to keep in mind as you prepare to gather your July 1, 2021 data:
Other considerations:
Do you develop a July 1 Mid-Year Monitoring Report?
Items 1-5 above are still relevant, although you’re only concerned with the previous 6 months of data! Items 6 & 7 can be ignored since we are measuring the mid-year progress since your January 1 annual plan.
Note, although you won’t receive a new narrative, item 5 above should still be completed. If you are more than 6 months into your plan when a OFCCP Scheduling Letter is received, the agency will ask for evaluations and assessments covering 18 months.
Do you use your July 1 data for compensation analysis?
Just like Items 1 and 3 above, be sure any pay changes have been entered with the appropriate date and you’re capturing the correct information. If your mid-year pay changes go into effect on July 1st, think about if the goal is to analysis your compensation prior to or after these changes; you may need to pull the data differently depending on the answer.
Do you use your July 1 data for VETS-4212 reporting?
Since the reporting period for VETS-4212 reporting can be any time between July 1 and August 31, save time by using the same data! This means you should be sure you have gathered Protected Veteran status for all current employees as well as any new hires from the previous 12 months. You will also need to be sure each employee and new hire has a work location identified. Remember, your VETS-4212 establishments may or (most likely) may not be the same as your plans. According to the DOL VETS-4212 site:
“Multiple establishment employers are those employers doing business at more than one hiring location. In addition to filing a completed VETS-4212 Report covering the principal or headquarters office, these employers must: File a separate VETS-4212 Report for each hiring location or state consolidated for each state employing 50 or more persons…”
“In addition to filing a completed VETS-4212 Report covering the principal or headquarters office, and separate VETS-4212 Reports for each hiring location within one state employing 50 or more persons, multiple establishment employers must either: File a separate report for each hiring location…or File state consolidated reports that cover hiring locations within one state that have fewer than 50 employees…”
Visit the VETS-4212 site for helpful FAQs regarding filing your reports.
COVID-19
Any plan after April 1, 2021 will now have the special circumstance of covering an entire year of the pandemic. Some unusual activity might have been captured in last year’s plan since we didn’t know how long any of it would continue at the time!
Did you have a hiring freeze? Did you have furloughs or RIFs? Have you brought employees back already? Depending on your industry, maybe you increased business in the prior year and had an unusually high number of job postings. Maybe your external recruitment areas have expanded, allowing for remote workers across the country. These are all things that should be considered and discussed with your Berkshire consultant so we can ensure your AAP reflects the workforce accurately.
Since plans covering the pandemic are just now starting to be scheduled for audits, we are still learning how OFCCP will handle any unusual personnel activities that occurred during this time frame. However, we believe since all employers faced unprecedented times, the agency will take unusual circumstances into account during their desk audits.
As always, Berkshire consultants will walk clients through these considerations as we review your data. Finally, as a reminder, our recommendation is to submit your data as soon as possible after your plan date! As soon as you are sure all personnel actions have been entered, and as soon as you are able to run your reports, please send us the data! It will be your 4th of July gift to us!