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Plans by Establishment

Anonymous - Jun 27, 2019
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Our organization has several small offices in over 30 states. Currently the way we run our plans is to roll all of those small office locations up to the state level and run one plan per state. The only exception to that rule is our headquarters which we run on its own given the number of employees tied to that facility. We know OFCCP states that establishments with 50 or more need a plan but we’re wondering…
1. what do we do with locations that don’t have 50 or more people, is rolling it up to the state level the best plan or do we not even need to roll those establishments up somewhere?
2. what guidance do you have about the risk we’re running by doing this on a state level vs. specific facility by facility.

1 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

Beth Ronnenburg, SPHR, SHRM-SCP

President, Berkshire Associates

Bill Osterndorf

President and Founder, HR Analytical Services

Carey Freitag

Human Resources Manager, Circa

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

Lisa Kaiser, Esq.

Managing Partner, The Kaiser Law Group, PLLC

Marilynn L. Schuyler, Esq.

Senior Counsel, Seyfarth Shaw

Matt Nusbaum

Senior Consultant, Director, Biddle Consulting Group, Inc.

William E. Doyle, Jr., Esq.

Former Deputy Director, OFCCP Partner, McGuireWoods LLP

Zoe Ann Whitley

Manager, Consulting Services, Affirmity

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