The OFCCP Digest Volume 7, Issue 10

Why I Hired a Workforce Others Overlooked Topic: Disability
For 16 years, I led the Logistics Division of Walgreens that included more than 10,000 employees and 17 distribution centers across the country. I am also the father of two daughters and a 28-year-old son with autism. As might be expected, I am more proud of the latter than any...more
	Randy Lewis Founder, NOGWOG Disability Initiative

Who Is a Protected Veteran or an Individual with a Disability? Topic: EEO
In my last article for the The OFCCP Digest, I wrote about the changing perceptions of race, ethnicity, and gender, and how these changes may affect regulatory compliance. For federal contractors and subcontractors, there are two remaining classes that are protected under...more
	Bill Osterndorf President and Founder, HR Analytical Services

Case of First Impression Under ADA Warns Employers About Telling Workers Too Much About EEOC Charge Topic: EEO
Oh oh, EEOC has just asked you for a list of names and telephone numbers for a large group of your employees. Why? The usual answer is because EEOC wants to interview at least some of them to see if they have evidence supporting the claims in a discrimination charge filed by...more
	Brian Bulger, Esq. Of Counsel, Cozen O’Connor

Best Practices: Applicant Disposition Codes Topic: Internet Applicant Rule
Applicant disposition codes are one factor that can potentially “make or break” Affirmative Action Plan (AAP) data. As a best practice, we recommend having detailed disposition codes that include two pieces of information for each candidate – the step and status...more
Stephanie Meyers Associate HR Consultant, Berkshire Associates

National Disability Employment Awareness Month Topic: Disability
Lately, my client roster is filling up with new federal contractors and I have been focused on getting them up to speed on all their new requirements. We focus on the elements of an AAP, recordkeeping, self-ID forms, posters, etc. When we are in the midst of making sure we...more
	Carla Irwin, Esq. President, Carla Irwin & Associates, Inc.

Ask the Experts is an online forum where federal contractors and subcontractors are invited to submit questions to industry experts related to OFCCP compliance, affirmative action planning, and equal employment opportunity. Simply register your company on LocalJobNetwork.com to submit a question. Questions and answers will occasionally be featured in The OFCCP Digest for the benefit of all readers.

Question: Staffing Agency Letter

I understand that we have obligations to notify staffing agencies about our federal contractor status, but what does that notification really ask? Are we putting them on alert that they need to send us diverse candidate pools, are we notifying them that they may have obligations as a sub-contractor or are we just satisfying a regulation? I send these letters out annually and don't really see the benefit other than we are meeting our compliance requirement. Can someone please explain the rule?

Answered by Marilynn L. Schuyler from Schuyler Affirmative Action Practice:

The purpose behind the rule is to ensure that the staffing agencies are keeping you compliant. As your sub-contractor, they need to be conducting outreach according to the federal contractor regulations. The notice itself is not the most critical issue. As a federal contractor, it is your obligation to ensure that the staffing agency is following the regulations, as though you were conducting the outreach for yourself.

EEOC Conducting New Training on Harassment Prevention

The Equal Employment Opportunity Commission (EEOC) has created a new program to provide unique training for harassment prevention in the workplace. This program includes two types of training conducted by the EEOC Training Institute: one designed for supervisors (Leading for Respect) and another geared toward all employees (Respect in the Workplace). This program emphasizes acceptable workplace conduct and behaviors which create a respectful and inclusive environment. The program is customizable for various types of workplaces and is an extension of the Report of the Co-Chairs of the EEOC’s Select Task Force on the Study of Harassment in the Workplace

Read more DOL Highlights throughout the month for timely updates.

Contact Us
The OFCCP Digest is a complimentary resource featuring affirmative action, equal employment opportunity, and government compliance topics. Previous editions are available for easy reference on The OFCCP Digest Archives page. To subscribe or to provide feedback, email OFCCPDigest@LocalJobNetwork.com.

The opinions expressed in this newsletter are the opinions of the individual author(s) and do not necessarily reflect the opinions of the Local JobNetwork™. The information appearing in this newsletter is meant to provide the reader with a general understanding of topics relating to OFCCP compliance requirements and is not legal advice. If you are seeking legal advice to address OFCCP compliance issues or requirements, you should consult an attorney. The Local JobNetwork™ expressly disclaims all liability with respect to actions taken or not taken based on any or all of the contents of this newsletter.