Recruitment Tip: OFCCP Audits, Applicant Tracking, and Management

When it comes to applicant management, Office of Federal Contract Compliance Programs’ (OFCCP) audit...

Posted by Charu Avasthy, PHR, Senior HR Consultant on June 20 2014
Charu Avasthy, PHR, Senior HR Consultant

When it comes to applicant management, Office of Federal Contract Compliance Programs’ (OFCCP) audits have gotten very intense in the past few years. Some of OFCCP’s most common post-audit questions focus on applicant data. The agency may request submission of applicant data by job group, and then dissect this data for accuracy and ask follow-up questions such as:

  • Why is the hire date before the application date?

  • Why are there no applicant pools for some requisitions?

  • Why are some new hires missing in the applicant data?

  • Do you include internal hires in your applicant flow?

  • Why are there multiple job titles recruited for under one requisition number?

  • Why are you including applicant data for cancelled requisitions or requisitions with no hires?

  • How do you apply the Internet Applicant Definition and is it consistently used?

  • You say you conduct targeted recruitment efforts to hire female engineers, yet why do you not have a single female applicant in the job group?

  • Can you show proof you have posted your jobs with an Employment Service Delivery System (ESDS)?

  • Do you conduct adverse impact analysis on applicant data?

To make sure you are ready to answer these questions, you need to ensure your company has a well- defined selection process that everybody understands and follows. Once the process has been defined, a tracking mechanism should be put in place. Effectiveness of your system(s) can only be evaluated when good data is at hand. Robust data is also useful in litigation or government audits. Importance and ease of electronic tracking cannot be emphasized enough at this point. Imagine manually pulling 400 applications associated with a requisition and pulling EEO forms for these applicants. Now add to this data for all requisitions and positions that were filled during the affirmative action plan year. The best way to mitigate this is an applicant tracking system (ATS).

Some of the benefits of electronic applicant tracking systems are as follows:

  1. Automatically manage job postings which will save you time by tracking where your jobs are posted, and then allow you to generate reports for audits and good faith effort tracking.

  2. Reviewing, screening, and managing applicants or applicant pools become a breeze with use of programmed disposition codes, requisition numbers, etc.

  3. EEO, Veterans and Individuals with Disabilities forms are built in, and based on your selection process you can solicit and track this information separately from the application itself.

  4. You do not have to worry about keeping up with the regulations or revamping your systems as your vendor will take care of this for you.

  5. You don’t have to worry about putting data together to do a mid-year review. Applicant flow logs are easy to generate, enabling you to conduct adverse impact analyses.

  6. Each time an application is created a date is registered, or each time a disposition code is assigned the candidate’s status gets updated.

  7. You can track referral sources for each applicant, and this allows you to conduct an analysis to see if your recruitment dollars are being well spent. For instance, if you are paying $5,000 a year to a job board but there are no qualified new hires in your data from that website, then you are better off investing the $5,000 elsewhere.

Applicant tracking compliance will continue to be an area of focus in audits this year. If you have an existing ATS, or are shopping around for one, it will be helpful to remember some of the common applicant tracking questions mentioned above to ensure your data can withstand the scrutiny—as well as making sure you can evaluate the effectiveness of your recruiting dollars!

To learn more about selecting the right applicant tracking system for your company, please click here.

For information on Berkshire’s leading applicant tracking system, BALANCEtrak, click here.

Charu Avasthy, PHR, Senior HR Consultant
Charu Avasthy, PHR, Senior HR Consultant
Charu Avasthy is a leading Senior Human Resource Consultant for Berkshire. With over ten years in the compliance industry, Charu is a subject matter expert in compliance regulations and she provides customized solutions to a national base of clients across a broad span of industries.

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