7 Ways OFCCP Might Examine Your Applicant Data and Applicant Tracking System

The importance of applicant tracking can be seen firsthand when there are applicant adverse impact o...

Posted by Heather Fountain on January 24 2024
Heather Fountain

The importance of applicant tracking can be seen firsthand when there are applicant adverse impact occurrences that come to light in an OFCCP audit. If your company is selected for an audit the OFCCP will require submission of applicant data by job group, and then analyze this data for adverse impact and ask follow-up questions such as:

  1. Why is the hire date before the application date?
  2. Why are applicant pools missing for some requisitions?
  3. Why are some new hires missing in the applicant data?
  4. Do you include internal hires in your applicant flow?
  5. Why are multiple job titles filled under one requisition?
  6. Can you show proof you have posted your jobs with an Employment Service Delivery System (ESDS)?
  7. 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 recruiters can understand and follow. Once the process has been defined, a tracking mechanism should be put in place. This is known as an applicant tracking system or (ATS). The effectiveness of your system will depend on the quality of the data input. Robust data will provide more accurate results when conducting adverse impact analyses. These types of analyses will give you a better understanding of where you should focus your outreach efforts. The importance of electronic tracking cannot be emphasized enough, especially for companies that experience recurring turnover in their workforce.

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

  • 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.
  • Reviewing, screening, and managing applicants or applicant pools become a breeze with use of programmed disposition codes, requisition numbers, etc.
  • EEO, Veterans and Individuals with Disabilities self-identification forms are built in, and based on your selection process you can solicit and track this information separately from the application itself.
  • You don’t have to worry about manually putting data together to do a review. Applicant flow logs are easy to generate, enabling you to conduct adverse impact analyses.
  • Each time an application is created a date is registered, or each time a disposition code is assigned the candidate’s status gets updated.
  • 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.

If you have an existing ATS, or are shopping around for one, consider 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!

Heather Fountain
Heather Fountain
HR consultant at Berkshire, specializing in affirmative action and compliance

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