The Storm Arrives

At HR Analytical Services, we have been predicting major changes in the way that the U.S. Department of Labor’s Office of Federal Contract Compliance Programs (OFCCP) would approach affirmative action compliance reviews. We are now seeing evidence of those changes. Among the recent requests that have been made of companies during OFCCP reviews are the following:

  • • Multiple companies have been asked to provide extensive compensation-related information on all employees
  • • Multiple companies have been asked for lists of employees with disabilities, including employees who did not self-identify as having a disability
  • • Multiple companies have been asked for proof of outreach efforts made to find persons with disabilities and veterans for specific open positions
  • • Companies have routinely been selected for on-site reviews, even when the company had a small number of employees at the relevant facility and/or a small number of hires at the facility
  • • Companies have been asked to provide screen shots demonstrating that positions were listed with the relevant state employment service office
  • • Companies have been asked to provide information on a group of pos