Hi Janet, I'm not sure exactly from the facts in your questions how things are set up at your company, but I hope this helps. Your company should track information on its selection process for these candidates described above in order to fulfill its federal contracting obligations. What is the pool of candidates the company selects from in order to send an individual to the hiring authority and why were some not selected to be sent? It should be relatively easy to disposition those that are not selected for submission. Dispositions allow the company to remove individuals from the pool (those that are not considered applicants) and from its analysis (those that are applicants, but were not competitive for the job for other reasons), but are not required by the regulations. In other words, the company is not in violation of the laws enforced by OFCCP if it does not have adequate dispositions of every applicant. (I'm not recommending this practice, but want to be clear on requirements.) The issue is whether the company needs to dispositions to more precisely analyze its data. Unless there is statistically significant adverse impact or alarming trends at this stage in the process, the precise dispositions are not absolutely necessary. Once the candidate gets to the end of the process where he or she is sent to the site, it is likely the individual would remain in both the analysis and the pool.

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.