Down the Rabbit HoleResponding to OFCCP’s In-depth

Audits

HELLO!I’m Allen Hudson

@HudsonMann

AGGRESSIVE“full-scale

enforcement”

FY 2013 CONCILIATION RATE

30.98%

reverseCan we

the trend?

1Beef Up Your

Initial Submission

2

3 4

Avoid CommonViolations

Other Requests Best Practicesfor Your Data

Beef upyour initial submission

ADD Theseto your initial submission

Good FaithEfforts

VETS-100a Job listingsamples

Job adsw/ eeo

statement

PurchaseOrder

Online Accessibility

language

“If you are an individual with a disability and require a reasonable accommodation to complete any part of the application process, or are limited in the ability or unable to access or use this online application process and need an alternative method for applying, you may contact phone number or

e-mail address for assistance.”

compensationdata at the ready!

have

• Employee ID• Gender• Race/Ethnicity• Job Title• Salary Grade or Band• Date of Hire• Last change in Grade• Last change in Title

• Part-time vs. Full-time• Exempt vs. Non-exempt• Contract Assignment• Base salary or rate• Hours worked (for PT)• Other paid allowances• Employee Location• Shift

Deep divethe

For each employee

CompensationPolicy

PositionDescriptions

Salary history

Performancereviews

Five daysin

Common violationsavoid

Mandatory job listings

screenshots

1st

Posting logs

2nd

3rd Parties

3rd

Good faith outreachNarrative

explanationOriginal

documentation

– Partnerships with local service organizations

– Linkage with the State Workforce Job Bank agency

– Partnership with Vocational Rehabilitation services

– Recruitment efforts at educational institutions to reach students who are covered veterans

Outreach Examples

– Job ads targeting veterans & individuals with disabilities

– Encouragement of subcontractor outreach efforts

– Veterans Administration job placement program participation

– On-the-job training opportunities

Outreach Examples

RECORDKEEPING

Expressions ofinterest

2 years’employment data

Failure to hire

Failure to hire

Adverse impact&

Failure to hire• Applicant flow log

• Copies of applications

• Job descriptions and qualifications

• Names of those involved in the interview process

• Description of hiring process

requestsother

Other Common Follow Up Requests

• Accommodation requests and dispositions

• Lists of employees who have self-identified as disabled

• Self-identification forms – pre & post offer

• Blank job application

• Employee Handbook and/or Policies

Physical & mentalWhen do you review

job requirements?

Physical exams?Do you require

Medical restrictions?Do any jobs have

EEO NoticesAre

posted conspicuously?

Review your aapHow often do you

with top management?

Best practicesfor your data

ATS

HRIS

promotions!Track

Voluntary&

involuntaryterminations

???

Thank you!ahudson@hudsonmann.com

creditsflickr photos

Arrows – Khairil ZhafriBooted car – quinn.anyaCow – Meneer ZjeroenDiver – cold_water_diverLaundry – codaData – puntxote

© Hudsonmann 2013

Noun project icons

Thomas le bas - BirdNick holroyd - Thumb

Dmitry baranovskiy - ClockPrerak patel - Document

Lance weisser - GaugeKen messenger - Trophy

Jon testa - BookThomas le bas - Pencil

Blake thompson - Shared interestDaniel shannon - computer