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Ask The Experts

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.

Sourcing Requisitions

Asked By Anonymous on Apr 16, 2024

Can you please provide me some information or content on how to effectively manage Sourcing requisitions and the candidates who apply to them? I have seen your information regarding evergreen requisitions, but what about requisitions that are created to build out a talent pool and aren’t necessarily tied to an opening. What is the best practice in managing those types of requisitions? We are a federal contractor looking to maintain compliance with OFCCP.

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ADA/accomodations

Asked By Anonymous on Apr 03, 2024

For ADA, how is it best to approach accommodations (best practices) – what font is required as well as what places it is required to be housed (job descriptions, etc.)? I received the checklist for accommodations – is there a training/best practices to audit and ensure fully compliant?

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EEO assignment assign to employees vs to a job

Asked By Anonymous on Apr 03, 2024

We are implementing a new HRIS system and our global team is recommending assigning EEO codes to the employee rather than assigning to a job on a job table. Can you help with explaining the risks involved in assigning the code to a person?

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OFCCP Guidelines for Job Fair Requisitions

Asked By Anonymous on Apr 03, 2024

As a part of our university relations programming, we engage in on-site and virtual activities (i.e. job fairs, speaking engagements, etc) with our partner universities. We leverage a pipeline job requisition in our Applicant Tracking System (Oracle Recruiting Cloud/ORC) which allows us to create a job posting to collect resumes from these universities. Since these job postings are really meant to be a tool to support these events, are we required to post to all state and diversity job boards or can we post only to the university job boards and still be within OFCCP compliance?

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OFCCP Compliance Best Practices

Asked By Laura Patriarca-Troyk on Mar 04, 2024

Hello,
We are going through an internal audit and will be making some updates to our procedures. We are an Environmental Consulting Firm and have a couple of Federal projects. We are updating our processes and would like some guidance on these questions. We use Circa and they recommended we reach out to the Experts and and the OFCCP. Thank you for your help.

1) Can you provide me with the updated OFCCP disposition code list/up to date standards? 2) For the Data management technique what is the recommended minimum number of expressions? I saw that it depends but what is the “best practice” 3) What is the purpose of the data management technique to help our TA team understand the reasoning behind the process 4) We receive unsolicited resumes from managers and hang on to them. When a position is opened – as long as we have a time stamp can we consider the resumes that were emailed to us? We would have them apply but what is the best practice to document that they sent a resume prior to others applying? 6) We are using the 3 day rule for job postings. Do we have to wait the 3 days before we can extend an offer? What’s the purpose of the 3 day rule? We sometimes have strategic hires and open a job for that reason alone – do we still have to wait to extend an offer after 3 days? What if we interviewed someone for a job but then realize they are more qualified for a different type of role – and open that job to hire them. Do we have to follow the 3 day rule in that situation and make a note as to why the job was opened or do we still have to wait 3 days before hiring them and make sure we interview another person under that req even if we don’t intend to hire them?

Thank you for your time
Laura

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Application

Asked By Anonymous on Nov 08, 2023

Do you need to have an employment application on file before sending an offer letter?

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High School Internship Program

Asked By Anonymous on Nov 01, 2023

We are a federal contractor that is starting a pilot high school internship program with a specific high school. I am wondering what compliance concerns we should be aware of if we are hiring our high school interns from a specific school(s). How do we make sure we have fair employment practices in this situation?

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Best Practices for Including Small Offices in AAP Program

Asked By Anonymous on Nov 01, 2023

We are an employer with offices across the country (and a establishment based AAP program). We have some larger offices and many smaller offices with less than 50 employees. Unfortunately, the smaller offices don’t logically “roll up” into other plans in their region (through a common supervisor or other mechanism). Is there a risk in pooling all our small offices in one region together and creating a “small office plan” for that region (with no larger office included)? What are the best practices for handling smaller offices given the OFCCP’s most recent practices around AAP certification and audit selection?

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US Citizenship Requirements

Asked By Anonymous on Sep 11, 2023

As a federal government contractor, there are times being a US citizen is required. I know we can’t mandate all employees be US citizens.
How do we know when we can make that requirement or not? What laws or Executive Orders cover when US Citizenship is a requirement?

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Regulation Regarding Deletion of Application from ATS

Asked By Anonymous on Sep 06, 2023

Hello, I am looking for clarification on an applicant request to delete their application from our ATS system, the applicant never interviewed for any positions for our company. I know the OFFCP has said we need to maintain materials related to candidate selection, including applications, interview notes, etc. Is there any clear guidance on deleting an applicant that never interviewed but submitted an application?

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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

Bill Osterndorf

Principal Consultant, DCI Consulting Group, Inc

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.

Lawyer, The Kaiser Law Group, PLLC

Marilynn L. Schuyler, Esq.

Senior Counsel, Seyfarth Shaw

Matt Nusbaum

Senior Consultant, Director, Biddle Consulting Group, Inc.

Stephanie Stahr

Senior HR Consultant, Berkshire Associates

William E. Doyle, Jr., Esq.

Former Deputy Director, OFCCP Partner, McGuireWoods LLP

Zoe Ann Whitley

Manager, Consulting Services, Affirmity

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