Just as the rest of the Department of Labor is making changes we now get changes from the OFCCP (Office of Federal Contract Compliance Programs) regarding affirmative action. Both Seyfarth Shaw and Freeman Mathis & Gary have sent out summaries of the proposed changes from the OFCCP. I am not going to cover the entire announcement, too much information. You can read Seyfarth Shaw’s announcement here. In summary, however, here are some of the changes:
- Redefines veteran catagories
- Redefines how job vacancies have to be listed and with what groups
- It defines “linkages” between companies and recruitment groups
- It redefines data collection.
- It requires hiring benchmarks.
- It requires offering self identification of veteran status
- It makes other procedural changes, such as timing of reviews and internal dissmination
- It adds more reasonable accommodation changes
- It makes changes in applicant notification
- and other changes in needed information.
I do want to spend some time on the fourth bullet point. The Seyfarth Shaw memo describes the quantitative measures that will be necessary for employer contractors to pay attention to. These measurements include:
- The total number of referrals the contractor receives from state employment services, the number of priority referrals of protected veterans it receives, and the “referral ratio” of protected veteran referrals to total referrals;
- The total number of applicants for employment, the number of applicants who are known protected veterans, and the “applicant ratio” of known protected veterans applicants to total applicants;
- The total number of job openings, the number of jobs filled, the number of known protected veterans hired, and the “hiring ratio” of known protected veteran hires to total hires; and
- The total number of job openings, the number of jobs that are filled, and the “job fill” ratio of job openings to job openings filled.
So if you have a Federal Contract of $100,000 or more and have 50 employees or more you will need to pay attention to this. You do have a chance to comment on this, since these rule changes are not yet set in stone. If you want to make a comment you can see the official announcement and find out how to make comments.
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