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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.

Do jobs listed in the Virgin Islands need to be posted on state job boards?

Asked By Anonymous on Oct 06, 2022

I realize the US Virgin Islands are US territories… do they fall under VEVRAA?

Answered on Jun 10, 2022

Alissa Horvitz, Esq. - Member Attorney, Roffman Horvitz, PLC

The answer is "no," and the citation is 41 CFR Section 60-300-5(a)(5). “The provisions of paragraphs 2 and 3 of this clause do not apply to the listing of employment openings which occur and are filled outside of the 50 states, the District of Columbia, the Commonwealth of Puerto Rico, Guam, the Virgin Islands, American Samoa, the Commonwealth of the Northern Mariana Islands, Wake Island, and the Trust Territories of the Pacific Islands.”

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File of Self-ID Forms

Asked By Anonymous on Jun 23, 2022

Can the Self-Identification forms for Protected Veterans and the Self-Identification forms for Disability all be filed together? I keep a notebook on each form by alphabetical order. But would like to make it one book for all. The all expire at same time. Can I do that? It would be nice to file new hires or terms into one book rather than 3 separate ones. They are not kept with the Personnel files.

Answered on Jan 01, 1970

- Vice President, Circa

The regulations under VEVRAA and Section 503 of the Rehabilitation Act do not state anything specific regarding where to house self-identification forms. However, any forms that would contain medical information typically is stored in file cabinet under lock and key. Both of these forms can be stored together but should be kept apart from the regular employee file and in a place that is secure and only accessible to persons needing this information for the preparation of required reporting (e.g....

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Asked By Anonymous on Apr 11, 2022

Our marketing team is receiving more questions around digital accessibility. Do you have any consultants or recommendations on a company we could use to provide training?

Answered on Apr 13, 2022

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

There are many organizations that not provide a review of websites for accessibility as well as perform remediation. The Job Accommodation Network and EARN have information regarding website accessibility. Organizations such as Hire Potential, The Sierra Group, and Audio Eye are just a few organizations who perform this type of service and employ individuals with disabilities to assist in conducting the accessibility review. Biddle Consulting Group performs training on accommodations, compliance with ADA/Section 503, and inclusive practices for individuals with...

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EEO-1 Location for Remote Workers

Asked By Anonymous on Apr 11, 2022

For EEO-1 reporting, we have typically included remote employees in their manager’s location. However, with more employees now working remotely, we are unclear on how this “roll-up” should be performed. For example, if an entire department’s hierarchy works from home, is it reasonable to simply include all of them in headquarters?

Answered on Apr 13, 2022

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

Remote employees would roll up to the location of their reporting manager. If the reporting manager is report, you can follow the line of reporting up to the next tier until it reaches a physical work location in which the remote employees can be rolled into. For many organizations with a remote managers, this would mean that they would roll up to the headquarters location.

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Recruiter Notes in ATS

Asked By Anonymous on Apr 11, 2022

Are we required to have recruiters enter their pre-screen/interview notes in the ATS or is this just considered a best practice?

Answered on Apr 13, 2022

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

The regulations under EO 11246 do not indicate that pre-screening/interview notes need to be maintained within the ATS. However, the OFCCP does expect contractors to maintain interview notes in some format for the required record retention period which is typically two years depending on the size of the company and amount of the federal contract. The OFCCP has posted FAQs regarding the internet applicant at the following site: https://www.dol.gov/agencies/ofccp/faqs/internet-applicants

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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

Principal Consultant, DCI Consulting Group, Inc

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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