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OFCCP Compliance Best Practices

Laura Patriarca-Troyk - March 4, 2024
Back to Ask the Experts

We are going through an internal audit and will be making some updates to our procedures. We are an Environmental Consulting Firm and have a couple of Federal projects. We are updating our processes and would like some guidance on these questions. We use Circa and they recommended we reach out to the Experts and and the OFCCP. Thank you for your help.

1) Can you provide me with the updated OFCCP disposition code list/up to date standards? 2) For the Data management technique what is the recommended minimum number of expressions? I saw that it depends but what is the “best practice” 3) What is the purpose of the data management technique to help our TA team understand the reasoning behind the process 4) We receive unsolicited resumes from managers and hang on to them. When a position is opened – as long as we have a time stamp can we consider the resumes that were emailed to us? We would have them apply but what is the best practice to document that they sent a resume prior to others applying? 6) We are using the 3 day rule for job postings. Do we have to wait the 3 days before we can extend an offer? What’s the purpose of the 3 day rule? We sometimes have strategic hires and open a job for that reason alone – do we still have to wait to extend an offer after 3 days? What if we interviewed someone for a job but then realize they are more qualified for a different type of role – and open that job to hire them. Do we have to follow the 3 day rule in that situation and make a note as to why the job was opened or do we still have to wait 3 days before hiring them and make sure we interview another person under that req even if we don’t intend to hire them?

Thank you for your time

0 Answer

Our Experts

Comprised of former OFCCP directors and respected thought leaders in OFCCP compliance, affirmative action, and EEO.

Ahmed Younies

President and CEO, HR Unlimited, Inc.

Alissa Horvitz, Esq.

Member Attorney, Roffman Horvitz, PLC

Allen Hudson, PHR, SHRM-CP

CEO, HudsonMann

Angel Fischer

Angel Fischer

Bill Osterndorf

Principal Consultant, DCI Consulting Group, Inc

Carla Irwin, Esq.

President, Carla Irwin & Associates, Inc.

Craig Leen

Board Member, Circa

David Cohen

President and Founder, DCI Consulting

Ellen Shong-Bergman

Former Director, OFCCP and Retired President, Ellen Shong & Associates,

Josh Roffman, Esq.

Managing Attorney, Roffman Horvitz, PLC

Julia Mendez Achee

Senior Consultant - EEO/Affirmative Action Division, Biddle Consulting Group

Lisa Kaiser, Esq.

Lawyer, The Kaiser Law Group, PLLC

Marilynn L. Schuyler, Esq.

Senior Counsel, Seyfarth Shaw

Matt Nusbaum

Senior Consultant, Director, Biddle Consulting Group, Inc.

Roselle Rogers

Vice President, Diversity, Equity, and Inclusion, Circa

Stephanie Stahr

Senior HR Consultant, Berkshire Associates

William E. Doyle, Jr., Esq.

Former Deputy Director, OFCCP Partner, McGuireWoods LLP

Zoe Ann Whitley

Manager, Consulting Services, Affirmity

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