Tips for Effectively Tracking Outreach Efforts

Federal contractors and subcontractors (referred to here as contractors) are required to analyze the...

Posted by Cindy Karrow, SPHR, SHRM-SCP, Managing Consultant on February 20 2023
Cindy Karrow, SPHR, SHRM-SCP, Managing Consultant
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Federal contractors and subcontractors (referred to here as contractors) are required to analyze their workforce data annually and set goals where appropriate. The regulations for Executive Order 11246, which requires analysis by race/ethnicity and sex, require that goals are set where the contractor’s workforce is less than would reasonably be expected when compared to the labor pool available from which to hire – referred to as underutilization. This analysis is referred to as a utilization analysis. The comparison is achieved through the Incumbency vs. Estimated Availability analysis. When underutilization is found, the contractor must set a goal. Contractors should show good faith efforts to communicate job openings for hires and promotions to qualified potential applicants represented in the underutilized groups. For example, if women are underutilized in a job group, contractors must take action to use outreach and recruitment efforts to communicate job openings to sources where qualified women would find out about the opportunities. You can read more about Establishment of Placement Goals in OFCCP’s Technical Assistance Guide for Supply and Service Contractors.

Contractors are also required to engage in ongoing good faith efforts to communicate opportunities to qualified individuals with disabilities and protected veterans.  While there is no Incumbency vs. Estimated Availability analysis for these two groups, there are requirements for measuring their representation in the workforce and/or the percentage of hires each year.   

OFCCP established a utilization goal of 7% employment of qualified individuals with disabilities.  The purpose of the goal is to allow contractors to measure and report the representation in their workforce.  Contractors are required to assess the effectiveness of their outreach and recruitment efforts every year and make adjustments if necessary.  This evaluation should be part of the AAP each year and must be submitted in a compliance evaluation.   You can find out more about the Utilization Goal in this OFCCP FAQ and in the above referenced Technical Assistance Guide. 

Contractors must also evaluate the effectiveness of outreach and recruitment efforts to communicate hiring opportunities to protected veterans.  Each year, usually at the end of March, OFCCP sets the Veteran Hiring Benchmark for contractors.   This annual evaluation measures the percentage of protected veterans hired compared to the total hires.  Contractors must also assess the effectiveness of their outreach and recruitment efforts for protected veterans each year. 

Here are some tips for tracking and evaluating your good faith outreach and recruitment efforts to aide your compliance efforts:  

  1. Document, document, document – Everything!
    Keeping accurate records is the best advice we can give you. OFCCP tends to have many follow-up questions during a compliance review. Our clients have received requests for documentation such as the following during reviews: 
    • Proof of outreach for job groups where there were goals during the previous year – especially if progress was not made on those minority or female goals.  
    • Proof of outreach to sources for qualified individuals with disabilities if there are job groups with less than 7% representation. Or if the employer is small (under 100 employees), proof of outreach when the entire company has less than 7% representation.  
    • Proof of outreach to sources for qualified protected veterans including to the state employment service delivery system (ESDS) offices where the jobs are located.  
    • Documentation should be detailed – names of sources, targeted audience, contact persons, email addresses, dates, brief description of the results (success or lack of success) of the contact or activity.

  2. It’s more than just Posting Jobs on a Board or Website
    Think and plan strategically when advertising or posting jobs. Where will you most likely find qualified and interested applicants? OFCCP is interested in seeing quality efforts versus quantity. In addition to posting jobs on relevant sites and ESDS, OFCCP encourages and expects you to develop relationships with effective outreach sources. These relationships can take many forms and here are some ideas: 
    • Sponsor or attend local community events, especially those focused on employment.
    • Invite community members or organizations to refer or assist with placement activities.
    • Visit the local job service office and meet with the Veterans Representative.
    • Invite referral sources to visit your site for an understanding of the job requirements.
    • Become a member of an Industry Liaison Group (ILG).  Find your local chapter listed on the National ILG website.
    • Network and use resources that are readily available. OFCCP’s website has resources to tap into.  Visit OFCCPs Employment Resource Referral Directory for possible sources. 
    • Attend webinars - visit Berkshire's Events and Webinars page for past and upcoming events.
  3. Evaluate the Effectiveness of Your Efforts
    We mentioned documentation in the first point. Evaluating the effectiveness of your efforts is equally important. Since you are already documenting activity and efforts, it will be easy to add a short evaluation of the results.  You should record the outcome (positive or negative), any resulting hires, and whether you will repeat the activity or continue the relationship. If an action, source, or activity is not effective, you next step is to make a change; find another source or action.
  4. Use Technology
     Technology has made our lives easier and more efficient in many ways. We can reach potential applicants anywhere in the US or possibly the world if we choose to. Managing the volume of job seeker and applicant interest can be overwhelming.  Ensure that you have a system that can manage responses that result from your efforts. Refer back to idea number one – documentation is key!
    An applicant management system that allows you to keep accurate and timely records plus evaluate selection decisions is a must. In addition, you can track your outreach in similar management systems. For example, Berkshire’s proprietary affirmative action software, balanceAAP, includes access to balanceREACH which allows our AAP clients to track, document, and evaluate their good faith efforts sources and activities. 

Outreach and recruitment efforts that are effective for your business and meet your compliance requirements are a win for everyone. 

Cindy Karrow, SPHR, SHRM-SCP, Managing Consultant
Cindy Karrow, SPHR, SHRM-SCP, Managing Consultant
As a Managing Consultant, Cindy Karrow, SPHR, SHRM-SCP specializes in developing AAPs, acting as liaison with the OFCCP, and delivering customized training.

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