Hi Melissa. As a federal contractor or subcontractor, your organization needs to make outreach efforts to recruit and employ minorities, females, protected veterans, and individuals with disabilities. Most of the current focus at OFCCP and in the federal contractor community is on the outreach for veterans and individuals with disabilities, since the requirements for outreach regarding these two groups changed greatly in the revised regulations that were issued in September of 2013. You asked about state-specific requirement for outreach. Any requirements devised by a state would only apply to your organization if your organization does contracting with that state. For example, if you have a contract with the state of Kansas, you would need to comply with any Kansas affirmative action requirements as well as any federal affirmative action requirements. OFCCP does not have state-specific requirements. Instead, the agency's requirements apply to each facility where you have employees. Thus, if you have federal contracts or subcontracts, and your organization has employees in locations in Missouri and Kansas, you would need to make outreach efforts in the areas in Missouri and Kansas where your company has facilities. If you have both federal contracts and state contracts, you would need to comply with both federal and state outreach requirements. It's important to note that OFCCP's regulations on veterans require contractors and subcontractors to list open positions with the relevant state employment service office (i.e. the relevant Employment Service Delivery System or ESDS office). Thus, if your organization has employees in Missouri and Kansas, you'll need to make contact with the state ESDS where the opening has occurred. The number of outreach contacts to make is not defined in the federal regulations. If you're having good luck finding minorities, females, veterans, and individuals with disabilities, your obligation to make outreach efforts is limited. If you're not having success in finding members of these protected groups, you'll need to determine the best way to draw these individuals into your applicant pools. One of the most important things you can do in this regard is to make personal contact with several organizations that work directly with minorities, females, and especially veterans and individuals with disabilities. The traditional approach where employers sent out e-mails or letters on a scattershot basis to many organizations without any personal follow-up is being looked on with disfavor by OFCCP. The time frame for making outreach efforts depends more on the success you're having in finding qualified minorities, females, veterans, and individuals with disabilities than it does on calendar year or AAP year. If you know that you're not finding members of protected classes, it's a good time to start making those personal contacts.

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.