How to Ensure Your Recruitment Practices Are OFCCP Compliant

THE CLEARED RECRUITING CHRONICLES: YOUR WEEKLY DoD RECRUITING TIPS TO OUT COMPETE THE NEXT NATIONAL SECURITY STAFFER.

The Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) protects the workforce, fosters diversity, and implements anti-discrimination regulations. OFCCP holds organizations that contract with the federal government responsible for observing the legal requirement to take affirmative action and good faith programs, and not discriminate on the basis of race, color, sex, sexual orientation, gender identity, religion, national origin, disability, or status as a protected veteran.

This applies to firing, but just as important pertains to hiring. Cleared recruiters need to ensure that the company’s recruitment practices are OFCCP compliant.

Because if you do end up on the courtesy notification that your organization could be selected to undergo a compliance review (Corporate Scheduling Announcement List), you will want to pass your audit with flying colors.

OFCCP COMPLIANCE CHECKLIST FOR DOD RECRUITERS

1. Job Descriptions: Defense contractors should perform audits regularly of all job descriptions and requisitions to remove potential biases because doing so will help the organization meet recruiting compliance if an audit comes up. At a minimum, every position should be listed on local and state employment agencies (unless it’s an executive position, position filled by a current employee, or short temp roles).
2. Hiring Data: Application data tends to be the most susceptible to violations because of the complexity (and time) of data tracking. Collecting and notating accurate applicant data has four primary components. Listed applicant data in your applicant tracking system can better tell the story for why each candidate wasn’t hired during the recruiting process i.e. didn’t meet basic qualifications, didn’t accept offer, failed the phone screen or technical assessment, etc.). You can even create disposition codes to show why an applicant wasn’t offered the job to make your comments in your ATS uniform.
3. Recruiting Outreach: Track your applicant/candidate sources and note outreach activities to showcase your outreach and recruitment efforts. Even though it’s not necessarily a requirement, you should follow the OFFCP’s Criteria for Evaluation to help assess your diversity recruitment initiatives and maintain 100% compliance. Reach out to groups within the protected statuses to ensure you are reaching all diverse candidates.
4. Know the Policy: Understand the Vietnam Era Veterans’ Readjustment Assistance Act (VEVRAA) listing requirements for protected veterans and take affirmative action to recruit and retain this population. Talk with your human resources department about other affirmative action programs the company has and apply those to your recruitment strategy.

Defense contractors must manage a progressively diverse workforce. Diverse candidates are a growing pool of talent joining the DoD labor market, and organizations must be proactive in recruiting from this candidate group that is critical to our national security. As a federal contractor, regulations enacted by OFCCP impact you and your diversity recruiting initiatives, and require contractors who do business with the federal government to make employment opportunities accessible to minorities, women, veterans and other talent that is traditionally considered to be under represented in the DoD workforce.