2018 was a very busy year for federal contractors. Before we ring in 2019, let’s take a stroll through some of the highlights and what can be done to prepare for another busy year.
CSAL letters and Scheduling Letters
Corporate Scheduling Announcement Letters (CSAL) were sent to contractors twice in 2018. OFCCP has been busy scheduling compliance reviews from both lists. We have received information that scheduling letters may still arrive in December or early January as OFCCP offices complete reviews in a more efficient manner than prior years. To find out if your organization is on either list, visit the OFCCP website using this link to the Freedom of Information Act (FOIA) Library.
Last January we provided advice about preparing your data for Annual AAPs. This advice is still great for 2019 preparation and below are some highlights, but you can see the full blog here.
Applicants & New Hires
- Ensure applicants are being surveyed for race, gender, disability, and Veteran status.
- Reconcile applicant flow with new hire information.
- Review applicant disposition codes for accuracy and to ensure they adequately explain the step in the process where the applicant left and hiring decisions.
Current Workforce & Job Groups
- Make sure employees included in data tables have a race and gender specified. If employees choose not to disclose their race and gender, race and gender for employees may be assigned based on other employment records or visual identification.
- Review job groups to account for any changes in the organization over the past year.
- Confirm that employee IDs are unique to each employee and are consistent throughout job or location changes.
Outreach & Recruitment
- Compile and evaluate the effectiveness of targeted outreach used in the past year for individuals with a disability and protected Veterans to ensure compliance efforts were implemented.
- Review placement goals from the previous year as well as the targeted sources used to make progress towards those goals.
- Confirm all required positions were listed on the state Employment Service Delivery System Service (ESDS) where the openings occur.
IWD status re-survey is due
Prepare to survey your current workforce for disability status! It has been almost five years since the regulations for Section 503 were revised. One of the new requirements is a survey of current employees to invite self-identification of disability status every five years. There is also a requirement to remind the active workforce in between surveys completed every five years that disability status may be updated at any time. Some clients have moved to a four-year survey cycle to address both requirements.
Acting Director Craig Leen has been busy since stepping into the lead role at OFCCP. He has issued directives promising transparency, creating an Ombud Service in the national office, outlining Early Resolution Procedures (ERP), providing information about Opinion Letters and Help Desk, and rescinding Active Case Enforcement (ACE) Procedures. Last week OFCCP received approval for a revision to the Scheduling letter to allow for focused reviews for AAPs for Individuals with Disabilities. Read more on each of these in our blog posts here.
We look forward to giving you more updates as 2018 transitions into 2019. Keep your eye on this blog!