There are two important considerations with respect to working with your third party staffing agency partners. First, make you sure you include in your staffing agency contracts an equal opportunity clause and make them aware you are a federal contractor. All federal contractors are required under all three regulations, as a condition of their federal contract, to include the EO clause in all contracts, subcontracts, and purchase orders. Federal contractors shall make the clause a part of the contract by citing the appropriate regulation(s) and include the following language in bold text (I’ll use VEVRAA in this example): “THIS CONTRACTOR AND SUBCONTRACTOR SHALL ABIDE BY THE REQUIREMENTS OF 41 CFR 60-300.5(A). THIS REGULATION PROHIBITS DISCRIMINATION AGAINST QUALIFIED PROTECTED VETERANS, AND REQUIRES AFFIRMATIVE ACTION BY COVERED PRIME CONTRACTORS AND SUBCONTRACTORS TO EMPLOY AND ADVANCE IN EMPLOYMENT QUALIFIED PROTECTED VETERANS.”
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.
In addition, when your staffing agency is undertaking selection for your open positions, make sure that the selection procedure they are utilizing is consistent with the Uniform Guidelines on Employee Selection Procedures (UGESP). Under Executive Order 11246, all federal contractors are required to follow these guidelines. You may want to specifically refer to the regulation 41 CFR Part 60-3 or use similar language, such as: “As an employment agency, you agree to devise and utilize a selection procedure that follows the standards in the Uniform Guidelines on Employee Selection Procedures.”
