Disposition codes are critical in a compliance review because they help define which job seekers should be in the data that federal contractors provide to OFCCP. Disposition codes vary by employer and types of position, so you may have to create specific codes based on the uniqueness of the job, and disposition codes are created on objective information. For example, “did not meet basic qualification – education” because the job may require a Bachelor’s degree, but the job seeker has an Associate’s degree. Effective disposition codes answer three questions: 1. What stage did the candidate fall-out? 2. Why did the candidate fall-out? 3. Who made the decision concerning the candidate’s final status? Here are examples of effective disposition codes: - Salary requirement too high – Recruiter 1 - Not willing to work required hours – Recruiter 2 - Not willing to work required shift – Recruiter 1 When creating and using disposition codes, think of your entire hiring process, including drug testing to improper submission of materials to withdrew from consideration. Employers should disposition all candidates; avoid dispositions that are vague such as “Not considered” because that doesn’t pinpoint why the candidate was not considered; disposition each candidate according to what happened to that candidate; and avoid the “mass dispositioning” of candidates where everyone except the candidate who was hired have the same disposition code. Maintain disposition codes in an applicant flow log, whether it’s in an applicant tracking system or file folders and ensure the codes are maintained accurately. This is especially important in preparing Adverse Impact Analysis, which is one of the areas that OFCCP pays special attention to when searching for systemic discrimination.

You can use this OFCCP audit checklist to ensure you're doing what is required to maintain OFCCP's regulations including VEVRAA, Section 503, and EO 11246. Or request a demo to streamline your compliance and recruiting efforts.