Now that the election results are in, it appears self evident that the path outlined in various regulatory and sub-regulatory proposals will continue to guide the enforcement efforts of the OFCCP. Some of the uncertainty of the pre-election period has been resolved so it is time to think seriously about what your company will need to do to best position itself to comply with whatever changes may be ultimately implemented. Many companies are hesitant to make costly changes to their electronic and other systems before the final version of these reform efforts are implemented. However, there is more that you can do than go to seminars and find out that no one has timelines or an inside track on what will really become law.
In the current climate, it is important to do more than simply run your IRAs and evaluate your AAP data from last year. A broader overall assessment that is separate from your routine AAP data crunching can go a long way toward preparing you to more quickly adapt to any new proposals along the lines of those already published. Your organization needs to closely review the latest version of each of the proposals: the revised scheduling letter, the Section 4212 Vets regulation, the Sec