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America’s Job Exchange 400 Minuteman Road, Andover, MA 01810

www.americasjobexchange.com

Preparing for OFCCP Compliance

Rathin Sinha

President, America’s Job Exchange

Patrick M. Nooren Ph.D.

Executive Vice President, Biddle Consulting Group

http://www.americasjobexchange.com/

http://www.biddle.com/

http://www.biddle.com/

Visit www.americasjobexchange.com/employer or Call 1-866-923-6284

Today’s Speakers

Patrick Nooren, PhD

Executive Vice President

Biddle Consulting Group, Inc.

[email protected]

Rathin Sinha

President

America’s Job Exchange

[email protected]

mailto:[email protected]



Disclaimer

Not a legal advice. The presentation is intended only to stimulate discussions among

job board operators and users relating to the recent developments and proposed

regulatory changes at the Office of Federal Contract Compliance Program (OFCCP).


Represents the benefits of job seekers and employees

• EO11246 – Equal Employment

• Section 503 - Americans with Disabilities

• VEVRAA/Section 4212 - Protected Veterans

Audits federal contractors and imposes corrective

actions if deficient

• Scheduling Letter, Information Request

• Desk Audits, On-Site Audits,

• Conciliation Agreement, Penalties, Debarment

The OFCCP enforces regulations relating Equal Employment & Affirmative Action

About OFCCP


Executive Order 11246

Post job vacancy announcements to expose them to a large

number of minorities, women, and underrepresented groups.

Section 503 of the Rehabilitation Act of 1973

Reach out to persons with disabilities and provide information

about job vacancy announcements.

Vietnam Era Veteran’s Readjustment Act

(VEVRAA/JVA)

List all employment opportunities with the appropriate

employment delivery system in the state where the job is located.

Companies must list job vacancy announcements to reach protected groups

Job Listing Outreach


Increased Importance

• New leadership

• Budget increase of 35%

• New hires of 200 Compliance Officers (CO)

Increased Enforcement

• Higher incidents of audits

• Aggressive litigation, Larger penalties

Strengthening Regulations

• Proposed new regulations

• Submitted revisions to current regulations

The OFCCP has gone through notable changes under the current administration

Recent Changes


Mandatory Job Posting and Outreach

• Mandates specific methods of internet job postings and distribution

• Mandates additional outreach with community based organizations

Data Collection and Tracking

• Pre-employment data collection for protected groups

• Effectiveness of recruitment efforts by source of candidates

Analytics

• Analysis of candidate availability and actual hiring, compensation

• Annual review of recruitment efforts relative to goals and benchmarks

Most of the proposed changes for recruitment can be grouped in the three areas:

Essence of Regulatory Changes


Requires Specific Recruitment Efforts

• Must engage in certain number of outreach and recruitment programs

• Send job listings to the local employment service offices e.g. 1-stop centers

• Develop and maintain ongoing relationship with local Veterans Representatives

• Enter linkage agreement with listed organizations for recruitment and training

• Consult with Employer Resources Section of the National Resource Directory

Requires Enhanced Data Tracking

• Initiate requests to have candidates self identify prior to job offer and collect data

• Track number of referrals from the state employment service delivery systems

• Track ratio of protected veteran referrals to total referrals & maintain data for 5 years

• Establish annual hiring benchmark and conduct annual review of recruitment efforts

Proposed Changes: Protected Veterans



Referrals

• The total number of referrals that the contractor received from applicable local/state

employment services

• The number of priority referrals of protected veterans from applicable local/state

employment services

• The ratio of priority referrals of veterans to total referrals (referral ratio)

Applicants

• The total number of applicants

• The number of applicants who identified as a protected veteran

• The ratio of protected veteran applicants to total applicants (applicant ratio)



Hires

• The total number of people hired

• The number of protected veterans hired

• The ratio of protected veteran hires to total hires (hires ratio)

Job Openings

• Total number of job openings

• Total number of jobs filled

• The ratio of jobs filled to job openings filled (job fill ratio)

All data must be maintained for five (5) years


Referral Ratio

Number of priority referrals of veterans =

25 = 2.5%

Total number of referrals 1000

Applicant Ratio

Protected veterans =

10 = 2.0%

Total applicants 500

Hiring Ratio

Protected veteran hires =

5 = 5.0%

Total Hires 100

Job Fill Ratio

Number of job opening filled =

200 = 28.6%

Total number of openings 700

Census Data:

Barrier Analysis

Hires Analysis

???



Requires Specific Recruitment Efforts

• Must engage in a minimum number of outreach and recruitment programs

• Send job listings to the local employment One-Stop Career Center

• Maintain ongoing relationship with local State Vocational Rehabilitation Agency

• Enter linkage agreement with listed organizations for recruitment and training

• Consult with Employer Resources Section of the National Resource Directory

Requires Enhanced Data Tracking

• Initiate requests to have candidates self identify prior to job offer and collect data

• Track number of referrals from the state employment service delivery systems

• Track ratio of disability referrals to total referrals & maintain data for 5 years

• Establish 7% as a hiring goal for this group and conduct annual review of progress

Proposed Changes: Individuals with Disabilities


Impact of Proposed Changes: Systems and Processes

The proposed changes will require modifications to:

• Applicant Tracking Systems (ATS)

• Human Resource Information Systems (HRIS)

• Applicant Self-ID forms

• Websites / employment portals

• Affirmative Action Plan metrics

• EEO-1 submittals

• VETS-100 / 100A submittals

• Contracts/linkage agreements

• Budgets!

Begin having conversations now . . . !


Cost of Implementation

Direct cost and adminsitrative burden

Effectiveness of Recruitment Methods

Source of candidates by specific efforts

Burden of Data Collection and Tracking

Collect, manage and protect data for privacy

Complexity/Inconsistency of Rules

Individual interpretation of regulations

Federal contractors are already feeling the challenge of compliance in the post

AJB era. The proposed changes impose additional requirements.

Business Impact on Proposed Changes


Successor to America’s Job Bank

Launched on the heels of termination of the AJB

program of DOL

Destination for Job Seekers/Employers to

Connect

Specializes in the recruitment of diversity candidates

and mid-level jobs

Leader in OFCCP Compliance for Recruitment

Specializes in veterans and disability recruitment

outreach and mandatory job listing

AJE is a leading provider of recruitment advertising and compliance solutions

America’s Job Exchange


The AJE solution is comprehensive and covers all related activities and processes.

Solution for OFCCP Compliance


Step 1: Job Exchange Data Preparation

Job data can be delivered

automatically to AJE using

XML, FTP, and other direct feed

processes.

Our solution includes free

account set-up and importing

of job data.

AJE can also import job

information directly from your

site using site-scraping

technology.


Step 2: Job Postings on AJE Network

Your job posting is

automatically shared with the

AJE network of job exchanges,

including niche sites that cater

to veterans, minorities, women,

and persons with disabilities.

Our national site ensures that

your job posting reaches our

diverse job seeker audience.


Maximum national exposure for your job listing

AJE National Exchange

www.americasjobexchange.com

AJE Community Exchanges

AJE Veteran Exchange

AJE Diversity Exchange

AJE Disability Exchange

AJE State Exchanges

Customized for all 50 states

Syndication on National Job Boards and

Social Media Channels

Indeed, Simply Hired, GlassDoor, Facebook, Twitter

AJE Job Network

The AJE Job Network is developed with personalized content and user experiences

for protected groups

AJE Job Network

http://www.americasjobexchange.com/


Step 3: Distribution to State Employment Delivery System

AJE distribution network

contains more than 5,000 state

employment delivery systems

as defined by the OFCCP.

Your job is distributed to the

appropriate states through a

combination of direct feeds to

individual states and manual

postings (if required by the

state).


Distribution network of 5,000 state employment delivery

systems as defined by the OFCCP

State Job Banks

Job feed to individual states

Manual job postings if required

State One-Stop Career Centers

Daily email to offices nearest to job location

Business representatives

Career counselors

Veteran representatives (LVER/DVOPs)

State Distribution Network

Our best-in-class network of partners and job exchanges includes thousands of

national, state, and community-based sites.

AJE State Distribution Network


Step 4: Distribution to AJE Partner Network

AJE partner network is made

up of hundreds of outreach

partner sites and hundreds of

community-based

organizations and government-

sponsored sites.

Our outreach network features

a strong representation of

diversity partners.


Distribution network of more than 5,000 outreach partners

and sites including these premier partners

Veteran Job Boards

www.VeteranJobs.Net

www.Jofdav.com

www.allveteranjobs.com

Disability Job Boards

www.disabilityjobs.net

www.disabledperson.com

Diversity Job Boards

www.asianhires.com www.africanamericanhires.com

www.alllgbtjobs.com www.allhispanicjobs.com

www.diversityjobs.com

AJE Partner Distribution Network

Our best-in-class network of partners and job exchanges includes hundreds of

national, state, and community-based sites.

Distribution network includes hundreds of community-based

organizations and government-sponsored sites

Goodwill

Local chapters

Easter Seals

Local chapters

The Arc

Local chapters serving persons with intellectual

disabilities

Department of Rehabilitation

Local state offices

U.S. Department of Veterans Affairs

www.va.gov

Community-Based Organizations Outreach Partner Network

http://www.veteranjobs.net/

http://www.jofdav.com/

http://www.allveteranjobs.com/

http://www.disabilityjobs.net/

http://www.disabledperson.com/

http://www.asianhires.com/

http://www.africanamericanhires.com/

http://www.alllgbtjobs.com/

http://www.allhispanicjobs.com/

http://www.diversityjobs.com/

http://www.va.gov/


Step 5: Online Reporting Portal

Our comprehensive online

reporting portal provides

accurate and detailed

recordkeeping for all of your

compliance activities.

You benefit from around-the-

clock access to activities and

reports that include posting

and distribution details and

clicks and applies from all of

our traffic sources.


Job and Distribution Details

Create reports for the company

as a whole or for specific

locations or subsidiaries.

Reports can be saved and

exported to PDF and Excel.

Detailed outreach and distribution

information, including delivery

method and date and time stamp.


Individual Job Records

Links to job descriptions on AJE exchange

sites along with links to outreach partner sites.

Individual job records provide the details on

distribution to our network partners and the states.


Individual Job Records

Links to emails and CSV files as evidence of

distribution to community partners and state

one-stop offices.

Jobs manually posted to the states include the

state confirmation ID in your report.


Account Dashboard

Job traffic results are available

in total or by source for all of

AJE’s traffic sources.


Job Manager

Job posting history is easily

accessible and up to date.

Track your posting patterns to

determine future needs.


Batch Feed Monitor

Monitor batch feeds to manage

performance and ensure your

job imports are successfully

received and processed.


Step 6: Audit Support Assistance

AJE provides time-saving

services and support so that

you can focus on what’s most

important: attracting top talent

and building a diverse

workforce.

We also provide assistance in

the event of an OFCCP

compliance audit.


Job Postings on AJE and the AJE Network of Job Sites

Listings that reach large concentration of minorities, women, veterans and the

disabled.

Job Postings to Niche Diversity Partner Websites

Listings that reach job seeker audiences in targeted communities of

minorities, women, veterans and people with disabilities.

Job Delivery to the Appropriate State Employment Systems

Automated job delivery to State Workforce centers, Career One Stop Centers,

LVERs and DVOPs, and CBO organizations.

On-Demand Audit Reporting with Custom Report Downloads

Shows record of job posting and delivery, related links and job description,

time and date stamps, and delivery confirmation.

To conclude, Federal contractors can obtain cost effective but complete solutions

from third party vendors such as America’s Job Exchange (AJE).

Cost Effective but Complete


Traffic Generation

Get traffic to jobs as well as career website through search

engine optimization (SEO) and search marketing (SEM).

Recruitment Brand Development

A full suite of media products for recruitment sourcing,

corporate branding, diversity branding and advertising.

Recruitment Technology Services

A full suite of technology services including data feed

preparation, career site development and hosting.

Audit Support and Document Management

Live customer service and assistance in the event of an

audit including consultation, and retrieval of past documents.

Solutions from AJE also provide additional products to bolster ROI of recruitment

media and advertising for diversity and inclusion.

Additional Benefits


AJE: Satisfied Customers


• GE

• Ford

• Citigroup

• ConAgra Foods

• Boeing

• Cisco

• Lockheed Martin

• Travelers

• Cigna

• Cummins

• Pepsi

• Ashland

• AECOM

• Hormel Foods

• NiSource

• St. Jude

• Avaya

• Pentair

• Synovus

• Harvard Medical

• Mantech

• Aerojet

• Medtronic

• PG&E Corporation

• Dominion Resources

• Kellogg

• ConAgra

• Parker Hannifin

• Jacobs Engineering

• State Street Corporation

• Sun Trust Banks

• Progress Energy

BCG: Satisfied Clients

Fortune 150 Fortune 151-300 Fortune 301+

Over 3500+ clients (600+ EEO/AA)

For more information, please contact:

Thank You

Rathin Sinha

[email protected]

Patrick Nooren

[email protected]




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