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Ask the Experts is an exclusive online forum provided by Circa. Federal contractors and subcontractors are invited to submit questions to industry experts related to OFCCP compliance, affirmative action planning, and equal employment opportunity.

Number of interviews by open requisition

Asked By BhlinerEE on Jan 28, 2022

I’m having trouble finding information specific to this question and hope you can help. Is there a rule or guidance that for each open requisition the number of interviewers has to be the same for all applicants that move forward? For example – my team has an open manager role, everyone that moves forward completes 3 interviews. Is this best practice or actually a law that the consistency has to be there.

Answered on Jan 28, 2022

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

There is no law that states all candidates being interviewed for open requisitions must go through the same number of interviews. In fact, it is common for higher level positions (e.g. senior management) to have more steps in the hiring process and more interviews than, for example, entry-level positions. Best practices for hiring processes do, however, include being consistent with the steps each candidate for a specific requisition must go through. If a written test is given to one applicant...

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1 Answer

Staffing Agency and OFCCP

Asked By Anonymous on Jan 27, 2022

If a staffing agency is a federal subcontractor, are they obligated to follow OFCCP guidelines when hiring temporary personnel for its clients ?

Answered on Jan 27, 2022

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

Staffing agencies which are subcontractors and meet the jurisdictional thresholds under Executive Order 11246, Section 503 of the Rehabilitation Act, and VEVRAA (see are required to follow regulatory requirements for their employees. Furthermore, one violation often found by staffing agencies which undergo OFCCP compliance reviews is lack of records. (See,applicants%20hired%20%2841%20CFR%2060-741.44%28k%29%29.%20%20HowLong.%20).

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Job Postings

Asked By Anonymous on Jan 26, 2022

If your job starts off as Unfunded and then moves to Funded, do you have to open a new job posting?

Answered on Jan 26, 2022

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

One way to consider handling this situation is to determine if the job duties, reporting manager, location of the job, and basic requirements of the job have stayed the same. If only the funding status has changed, you might determine to not create a new requisition. Any candidates that previously had applied for the position, however, would still be considered candidates for the job requisition. However, if changing the funding status changes any job duties, requirements, location of the job,...

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In Person vs. Virtual Interviews

Asked By Anonymous on Oct 09, 2021

Is it inappropriate or a potential discrimination to conduct some interviews in person and some via virtual platforms? (Zoom, Skype, etc.)

Answered on Oct 01, 2021

Beth Ronnenburg, SPHR, SHRM-SCP - President, Berkshire Associates

I don't believe it is inappropriate or potential discriminations to conduct some interviews in person and some via virtual platforms. I would recommend that the questions and format be consistent and the fact that it was in person or virtual should not play into the decision as to the candidates qualifications.

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This forum provides information of a general nature. None of the answers or information provided is intended as legal advice or opinion relative to specific matters, facts, situations, or issues. Additional facts and information or future developments may affect the subjects addressed. You should consult with an attorney about your specific circumstance before acting on any of this information since it may not be applicable to your situation. Circa and all experts expressly disclaim all liability with respect to actions taken or not taken based on any or all of the contents of this forum.

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

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.

William E. Doyle, Jr., Esq.

Former Deputy Director, OFCCP Partner, McGuireWoods LLP

Zoe Ann Whitley

Manager, Consulting Services, Affirmity

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